The Customer Who Wants to Move £250,000 Quickly
A relationship manager at a UK bank receives instructions from a long-standing business customer, a small property company, to transfer £250,000 to an account in a jurisdiction the bank classifies as higher risk. The customer says the funds are for a property deposit and asks for same-day execution. The account has been dormant for 11 months and was reactivated two days ago. The authorised signatory is the company's sole director, who has just returned from abroad and is emailing from a new address. The bank's records show the company's stated business is residential lettings. The relationship manager has known the director for six years and considers him trustworthy. The bank's policy requires enhanced due diligence for transfers above £100,000 to higher-risk jurisdictions, and a callback to a verified number for any change of contact details.
1. Should the relationship manager process the transfer today? Justify your answer by reference to the risk factors.
Read the worked answer
No - not today, and not on the current information.
The manager should not let the personal relationship override the controls. Risk factors present:
- Dormancy and reactivation - an 11-month dormant account reactivated two days before a large transfer is a recognised red flag.
- Size and destination - £250,000 to a higher-risk jurisdiction exceeds the bank's own EDD threshold.
- Change of contact details - a new email address is an unverified channel; the policy expressly requires a callback to a verified number.
- Purpose mismatch - the stated business is residential lettings; a property deposit abroad may or may not fit, and the manager should test it, not assume.
- Single signatory - one director authorising a large outbound payment reduces the internal check on the customer side.
What to do:
- Complete the required enhanced due diligence before any payment.
- Perform the callback to the number on file, not the number in the new email.
- Obtain and record source-of-funds and purpose evidence.
- Escalate to the financial crime/MLRO function for a decision; do not make the call alone.
- If the request is legitimate, it can be processed once verified - the delay is a control, not a refusal.
2. The director is annoyed and says: 'We have banked with you for 20 years. Are you calling me a criminal?' How should the manager handle the conversation while maintaining the control?
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The manager should separate the relationship from the control:
- Acknowledge the long relationship sincerely and thank the director for it.
- Explain that the checks are triggered by the transaction profile, not by suspicion of the individual - dormancy, size, destination and a new contact channel would trigger the same steps for any customer.
- Avoid language that sounds accusatory; use 'our process requires' rather than 'we doubt you'.
- Be clear and honest about timing: say what is needed and roughly how long it should take, without promising same-day execution that the manager cannot guarantee.
- Offer practical help: a named contact, a list of the documents needed, and an offer to prioritise once received.
- Do not disclose tipping-off-sensitive information or promise to 'push it through'.
The manager should also record the conversation. The goal is to keep the customer while keeping the control - the two are not in conflict if the conversation is handled professionally.
3. What should the manager document, and why does documentation matter here?
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Document:
- The instruction received, the channel, and the time.
- The new email address and the fact that it differs from the record.
- The callback: the number used, who answered, and what was confirmed.
- The EDD evidence obtained (source of funds, purpose, identity verification).
- The rationale for the decision to proceed or hold, and who approved it.
- The escalation to the financial crime function and its outcome.
Why it matters:
- It provides the audit trail that shows the bank applied its controls.
- It supports the defence if the transaction is later questioned by the regulator or law enforcement.
- It protects the individual manager, who can show they followed policy rather than acting on personal trust.
- It creates a record that can be reviewed if the customer relationship changes or a pattern emerges.
Undocumented judgement is indistinguishable from no judgement when reviewed later.