Collection Agency

Recognizing unusual transactions

As a service provider – debt collection agency – you are familiar with the practices within your line of business. Whether a transaction is considered unusual depends largely on your professional judgment. Your judgment is consistent with what is considered unusual within your profession. In addition to your judgment, there are situations that are unusual by nature and should therefore be reported.

IIf a situation arises as described in the examples below (not exhaustive), this is a reason to further examine whether the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses. It is not necessary to determine with certainty that the above-mentioned crimes have been committed. You merely need to have an assumption that the transaction can be related to one of these crimes.
If you believe that the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses, you are required to report this under the subjective indicator.

Red flags – Collection agency

• The client pays in cash (in small denominations, with uncounted money, in unusual packaging);
• The client gives objects as a security (collateral), which unmistakably originates from a crime
• The client often gives objects as a security (collateral) but does not pay off his debt or shows no interest in paying off the loan or obtaining his objects. The client provides objects as a security (collateral) far below the market value of those objects