Overview
As part of every Commercial Source of Funds review, Legl automatically runs five anomaly checks against all bank statements and accounts it was able to analyse. These checks surface patterns that may warrant further investigation and are designed to help you identify risk factors quickly, without manually reviewing every transaction.
Anomaly checks are not a definitive assessment of risk. They are indicators to inform your judgement as part of your overall AML review.
Where you will see this
Anomaly check results appear in the Bank statement anomalies section of the Commercial Source of Funds review page. Each check shows whether it was triggered, and if so, provides detail on the transactions or patterns behind it.
The five anomaly checks
1. Closing bank statement does not cover the declared amount
This check flags where the closing balance shown in the bank statement does not appear sufficient to cover the amount the client has declared they are contributing.
This may indicate that the client has overstated their contribution, that funds have already been transferred out, or that the bank statement provided does not represent their full financial position.
2. Large round number of credits
This check flags where there are multiple large credits into the account that are round numbers (for example, multiple transactions of £50,000 or £100,000).
A single round number credit may not be significant. Multiple round number credits can be a pattern associated with structured deposits or other activity that warrants further investigation.
3. Credit pattern does not match declared source
This check flags where the pattern of incoming transactions does not appear consistent with the source of funds the client has declared.
For example, if a client has declared a director's loan as their source but the bank statement shows no corresponding credit from a business account, this check may be triggered.
4. Large single credit (positive verification)
This check identifies where a single credit into the account appears to account for the declared contribution amount. Rather than a risk flag, this is a positive verification indicator: Legl has identified a transaction that appears to be the source the client declared.
This check is useful for confirming that the declared source is visible in the bank statement data.
5. Pass-through funds
This check flags where funds appear to have entered the account and then left again quickly, without remaining in the account for any significant period.
Pass-through patterns can indicate that funds have been moved through the account to obscure their origin, which may require further investigation.
What you need to do
The anomaly checks are indicators to support your review, not decisions made on your behalf. Where a check is triggered, review the underlying transactions using the detail provided, consider whether the explanation is consistent with what you know about the matter, and document your assessment as part of your AML file.
If you require further information from the client, you can follow up directly outside of Legl.
Important information
Anomaly checks only run against bank statements and accounts that Legl was able to analyse. If a client uploaded a bank statement that could not be processed automatically, that source will not be included in the checks.
A triggered check does not mean a transaction is suspicious. It means it is a pattern that warrants your attention.
Checks that are not triggered are still displayed in the review, so you can confirm that each one has been assessed.