Which of the following is a red flag for victim accounts, such as in trafficking cases?

• A. Excessive travel/fast food related payments
• B. Regular payroll
• C. Normal mortgage payments
• D. Low-risk balance

Answer: (D)

In AML practice, red flags for victim accounts in trafficking cases hinge on unusual money movement patterns rather than single normal activities. A low-risk balance stands out because it suggests funds aren’t being kept in the account for long; money is being moved quickly through the account or dispersed to other places. This rapid turnover and minimal retained balance is a tactic used to hide the flow of funds and avoid drawing attention, which is a common feature of trafficking-related money movement.

Other patterns can occur in legitimate contexts or be less definitive on their own. Regular payroll and normal mortgage payments can look like normal, legitimate activity, and while unusual travel or frequent small payments might raise questions in some cases, they don’t as reliably indicate trafficking as the consistent pattern of sustaining ongoing activity with a persistently low balance.