Wishes to hide their identity, favours anonymity or is unduly secretive

Has an unnecessarily complex structure

Has changed advisors frequently for no apparent reason

Has been refused service by other accountants or is willing to pay more than normal for the service

Has transactions that do not make sense

Is engaging us for only one transaction

Has a lifestyle inconsistent with what we know about them

Is a cash-based, or cash-intensive business

Has multiple bank accounts or foreign accounts with no justification

Is taking on work outside their normal range of operations

Has a high turnover in relation to the size of their operations

Is overly focused on reducing or avoiding the payment of tax

Has high net worth individuals

Is uncooperative

Has known criminal or terrorist connections

Has changed their business operations significantly during COVID

Has links to proliferation financing

Has Politically Exposed Persons

Appears on the Treasury Consolidated Sanctions list

Operates in countries with connections to proliferation financing

Is Insolvent

Has aggressive tax schemes

Is a Trust

Is an investment business

Provides Payroll services

Provides Probate and estate management services

We will be providing Accounting services based on records that could potentially be falsified

Insists on using our services for transactions outside our normal business operations

Is the formation of a company with no ongoing services

Utilises, or asks to utilise, our client bank account for transactions other than routine business refunds

Wants to set up deals involving large amounts of cash

Has significant funds for investment and will accept higher risk and lower returns than normal

We have not met face to face

All our services are provided on-line

Were previously unknown to the firm and will travel great distances to use us with no commercial justification

We have relied on other’s CDD in respect of a written reliance agreement