Product/Customer transactions suspicious activity indicators

1. Transactions do not have apparent economic rationale.
2. Transactions appear to be undertaken in a structured, sequential manner in order to avoid transaction monitoring/reporting thresholds.
3. A concentration ratio of transactions relating to a particular and/or higher risk jurisdiction that is notably higher than what is to be expected considering its normal patterns of trading of a customer.
4. Frequent trades resulting in losses for which the customer appears to have no concern.
5. Sudden spike in transaction volumes, which deviates from previous transactional activity absent any commercial rationale or related corporate action event.
6. Mirror trades or transactions involving securities used for currency conversion for illegitimate or no apparent business purposes.
7. A pattern of securities transactions indicating the customer is using securities trades to engage in currency conversion. Examples of securities that can be used in this manner include dual-currency bonds, American Depositary Receipts (ADRs) and foreign ordinary shares traded in the Over-the-Counter Market.
8. Securities transactions are unwound before maturity, absent volatile market conditions or other logical or apparent reason.
9. Trading or journaling in the same security or securities between numerous accounts controlled by the same people (e.g. potential wash sales and/or directed trading).
10. Two or more unrelated accounts at the securities firm trade an illiquid or low- priced security suddenly and simultaneously.
11. Purchase of a security does not correspond to the customer’s investment profile or history of transactions (e.g. the customer may never have invested in equity securities or may have never invested in a given industry) and there is no reasonable business explanation for the change.
12. Transactions that suggest the customer is acting on behalf of third parties with no apparent business or lawful purpose.

13. Funds deposited for purchase of a long-term investment followed shortly by a customer request to liquidate the position and transfer the proceeds out of the