Four environments, one review standard.

1. Set document requirements by customer type, product, jurisdiction and geography.
2. Collect documents and data.
3. Verify the customer, related parties and beneficial owners; for businesses, registers, filings and control.
4. Screen for PEP, sanctions and adverse media.
5. Establish source of funds and wealth where needed.
6. Set the risk rating.

Hard parts Thin files, partial ownership chains, nominee directors, conflicting documents, PEP hits on common names.

1. Review the alert against the customer profile and prior alerts.
2. Analyse transactions, counterparties and wallet exposure.
3. Identify red flags; match or rule out a typology.
4. Request information if needed.
5. Write up the rationale.

Hard parts Unusual but explainable activity, patterns split across accounts, evidence arriving in stages.

1. Compare the hit with the list entry’s identifiers.
2. Decide true match or false positive, and record why.
3. Check ownership and control.
4. Review the payment route, intermediaries and goods.

Hard parts Transliterated and common names, split ownership, exposure through intermediaries.

1. Review device, login and behaviour signals.
2. Check the payment against history and payee.
3. Identify the pattern: account takeover, APP scam, mule or first-party fraud.
4. Weigh the loss against turning away a genuine customer.

Hard parts Victims who authorise the payment, mules who look like new customers, first-party fraud posing as a dispute.