CC-101 · Lesson 4 · Red flags in our sector

One flag is a question. Three is a pattern.

The hard part is not spotting something odd. It is what you do in the twenty minutes afterwards, when the innocent explanation starts to sound reasonable.

23 September 2026 · Amanda Dunn · 4 min read

Everyone worries they will miss something. In practice the more common failure is noticing it and then reasoning it away — because the customer was pleasant, because the deal is nearly done, because you would feel ridiculous raising it.

A few things make that easier to handle.

Indicators are not accusations

An indicator means "this is the kind of thing that sometimes accompanies financial crime". It does not mean this person is a criminal. Plenty of people pay in unusual ways, buy through structures, or are in a genuine hurry.

Holding that properly in your head is what stops the two failure modes: treating every oddity as an emergency, and treating none of them as anything.

Look for combinations

A single flag is usually a question worth asking. Several at once, particularly from different families, is a pattern — and patterns are much harder to explain away.

An overseas buyer is ordinary. An overseas buyer, purchasing through a company with no trading history, paying well over the asking price, who will not meet in person, is a different conversation.

There is no magic number. Two strong indicators can matter more than five weak ones, and a single thing can be serious enough on its own. If you find yourself counting to justify not raising it, that is the signal.

Record what you saw, not what you concluded

This is the habit worth building. "Buyer declined to meet in person on three occasions and asked whether the deposit could be paid in instalments from different accounts" is useful. "Buyer seemed dodgy" is not — it cannot be assessed, and it will not mean anything to anyone reading it later.

Facts, dates, what was actually said. Leave the conclusion to the person whose job it is.

Trust the feeling, then evidence it

Experienced agents often sense something before they can name it. That instinct is worth taking seriously — but it is not something anyone can act on until you translate it into what you actually observed. Write down the things that produced the feeling.

Notice and escalate. Do not decide. →What happens after you raise it, and why the call is not yours.

Where Curlew fits

The observation needs somewhere to go at the moment you have it, or it evaporates. Curlew lets you flag unusual activity against the customer record and work the enhanced due diligence from there, so what you noticed is attached to the file rather than sitting in a sent-items folder.

The decision still belongs to your compliance officer. The system just makes sure they are looking at what you actually saw.