This half-day training helps private bankers and wealth managers detect and manage AML risks in cross-border transactions for high-net-worth clients. Through practical case studies and interactive exercises, participants will learn to spot red flags, analyse complex wealth flows, and escalate concerns effectively—all while maintaining strong client relationships.

• Team leads
• Relationship managers, assistant relationship managers
• Front office customer service officers
• Wealth KYC team

Recommended for: Private Banking & Wealth Management

By the end of the session, private bankers and wealth managers will be able to:

1. Recognise AML red flags specific to high-net-worth (HNW) clients and cross-border wealth flows.
2. Apply detection techniques when reviewing client instructions, investment flows, and transactional behaviour.
3. Analyse private banking case studies to spot unusual patterns that may indicate money laundering.
4. Document and escalate concerns effectively to compliance teams, balancing client relationship management with regulatory duties.

Welcome & Introduction

• AML in private banking: why HNW cross-border wealth is high-risk
• Outline of session flow

1. Quick Refresher: AML Risks in Private Banking

• Stages of money laundering & relevance to wealth management
• Regulatory backdrop (FATF, MAS, HKMA, EU directives)
• Notable private banking AML failures (e.g., 1MDB, Credit Suisse Mozambique case, $3bil Fujian)

2. Detection Focus: Private Banking Red Flags & Typologies

Common typologies in private banking cross-border transactions:

• Use of private investment vehicles, trusts, and offshore entities
• Complex layering across multiple accounts/jurisdictions
• Trade-based transactions tied to family offices/business holdings
• Real estate purchases through shell structures
• Cross-border movement of crypto-linked wealth

Red flags for relationship managers & wealth advisors:

• Clients reluctant to provide source of wealth/funds clarity
• Sudden inflows inconsistent with client profile or stated investment objectives
• Funds routed through secrecy havens without clear rationale
• Frequent cross-border transfers with no economic purpose
• Structuring of investments to avoid reporting thresholds

3. Tools & Techniques for Detection

• Transaction & client activity monitoring: RM’s role vs. compliance
• Enhanced Due Diligence (EDD): when and how to apply
• Using sanctions, PEPs, and adverse media screening in client interactions
• Practical do’s & don’ts in private banking monitoring (e.g., documenting client conversations, spotting inconsistencies)

4. Case Studies & Group Exercise

Case Study 1: Offshore Entity Structure

• HNW client sets up layered offshore companies for “investment diversification.”
• Exercise: Identify suspicious ownership opacity & wealth movement.

Case Study 2: Large Cross-Border Transfers

• A client requests multiple transfers to family members in high-risk jurisdictions.
• Group discussion: What’s unusual? How to engage client without raising suspicion?

Case Study 3: Crypto Wealth Conversion

• Client converts significant crypto holdings via an offshore exchange, wires funds to private banking accounts.
• Exercise: Assess risks, detection points, escalation steps.

(Each case followed by group debrief: What should be flagged? How to handle conversation with clients? How to escalate internally?)

5. Escalation & Reporting in Private Banking

• Role of private bankers in documenting concerns
• How to escalate discreetly while managing client relationships
• Elements of an STR/SAR: what RMs should (and shouldn’t) include
• Importance of timely escalation to compliance/FIU

6. Wrap-Up & Q&A

• Key takeaways: typologies, client-facing red flags, escalation best practices
• Discussion of participants’ real-world challenges with clients
• Closing remarks & further resources

7. Assessment – MCQ