Quick-Start AML Scenario Bundles

• Role-Play Based AML Training

  1. Suspicious Cash Deposits
     Scenario: A familiar customer arrives with multiple envelopes of cash, each just under $10,000, and makes light conversation while you process the deposits.
     Goal: Engage the customer politely while recognizing the structuring pattern, verify transaction details, and communicate your need to escalate discreetly without arousing suspicion.
     
     
  2. Unusual Wire Transfers
     Scenario: A new small-business client calls requesting several same-day international wire transfers to unrelated recipients and pushes to “get it done fast.”
     Goal: Speak with the customer to confirm the purpose of each wire, apply enhanced due diligence questions naturally, and document findings before proceeding.
     
     
  3. Customer Refuses ID Verification
     Scenario: A walk-in customer becomes defensive and raises their voice when you request identification for a large cash transaction.
     Goal: Calmly explain the verification policy, de-escalate the tension, and maintain professionalism while enforcing ID requirements.
     
     
  4. Foreign Beneficiary Anomaly
     Scenario: A long-time retail customer suddenly asks to send a large transfer to an unfamiliar offshore beneficiary.
     Goal: Ask conversational, open-ended questions to understand the purpose, confirm consistency with their profile, and explain why additional due diligence is required.
     
     
  5. Shell Company Concerns
     Scenario: A representative for a new corporate client hesitates to share details about ownership and insists the paperwork “isn’t important.”
     Goal: Communicate the regulatory necessity of naming beneficial owners, build rapport while maintaining firmness, and delay account setup until full details are obtained.
     
     
  6. Suspicious Real Estate Transaction
     Scenario: A client insists on using third-party checks to fund a real-estate purchase and becomes impatient when questioned.
     Goal: Speak directly about source-of-funds requirements, clarify that verification protects all parties, and pause the process until compliance clears it.
     
     
  7. High-Risk Business Type
     Scenario: A new client applying for a business account casually mentions they operate a cash-heavy venture like a car wash or ATM network.
     Goal: Engage the customer with friendly but targeted questions about operations, confirm documentation, and explain the monitoring steps required for high-risk accounts.
     
     
  8. Charitable Organization Misuse
     Scenario: The treasurer of a small nonprofit proudly describes a sudden surge in donations and requests a large overseas transfer.
     Goal: Show interest while asking validating questions about donation sources and recipients, confirm records, and explain compliance checks in a supportive tone.
     
     

  9. Refusal to Provide Source of Funds
     Scenario: A client initiating a large transfer becomes evasive when you request documentation of the fund source, saying “you’re overcomplicating things.”
     Goal: Maintain a respectful but firm conversation, restate regulatory obligations, and politely decline to proceed until documentation is complete.