Suspicious Activity & Internal Escalation
Building a culture where concerns are raised, not ignored
Internal escalation
Every staff member must know how to escalate a concern internally — typically to the compliance officer or MLRO. Escalation is confidential and protected; staff should never fear raising a concern.
Suspicious activity indicators
Suspicion does not require certainty. If something feels inconsistent, evasive or unusual, raise it. Common indicators include:
- Reluctance to disclose UBO
- Funds from unexpected jurisdictions
- Transaction structure with no commercial logic
- Pressure to bypass standard procedures
- Inconsistent client information across documents
Documentation matters
Document what you saw, when, and what you did about it. Internal records are critical for demonstrating compliance and protecting the firm.
Never ignore concerns
Failing to escalate is itself a compliance failure. A culture that protects whistle-blowers and escalators is the foundation of effective AML.
Official sources for this module
Primary publications from SEPBLAC and the Spanish Tesoro underpinning the material above.
- TesoroPDFCatálogo de Indicadores de Riesgo — Inmobiliarias
Indicators to consider when deciding whether an observation warrants internal escalation.
- TesoroPDFTipologías Delictivas
Recognising patterns that historically signalled suspicious activity in the sector.
See the full list on the Sources page.