FINRA AML Guide - Cert Deposit

From the FINRA proposed Anti Money Laundering Template for broker-dealers #1

b.	Red Flags
Red flags that signal possible money laundering or terrorist financing include, but are not limited to:
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Certain Deposits or Dispositions of Physical Certificates

• 	Physical certificate is titled differently than the account.

• 	Physical certificate does not bear a restrictive legend, but based on history of the stock and/or volume of shares trading, it should have such a legend.

• 	Customer’s explanation of how he or she acquired the certificate does not make sense or changes.

• 	Customer deposits the certificate with a request to journal the shares to multiple accounts, or to sell or otherwise transfer ownership of the shares.