Finance and accounts teams often see the warning signs first.
AML compliance is usually described as a specialist job, but finance and accounts teams often see the warning signs first, long before any formal AML review.
1. Payments that do not match the invoice. A vendor invoiced in one country but paid from an account in another, with no clear business reason, is a classic layering technique.
2. Round amounts just under reporting thresholds. Genuine business payments rarely land on suspiciously clean numbers just below a limit, again and again.
3. New customers or vendors pushing for urgency. Pressure to skip onboarding or due diligence "just this once" is a common social-engineering tactic.
4. Ownership structures with no commercial logic. If you cannot explain in one sentence why a counterparty needs three layers of shell companies, escalate it.
5. Cash activity that does not fit the business. A consulting firm receiving large cash deposits does not match what it says it does.
None of these proves wrongdoing alone. But finance staff who know to flag them, instead of explaining them away, are the first line of defense that any AML programme relies on.