Red Flags in Peer-to-Peer Transactions
The peer-to-peer transaction red flags compliance teams look for.
The list
- Fresh wallet with no history receiving funds
- Structuring - payments split to stay under thresholds
- Counterparty jurisdiction in an embargoed region
- Rapid pass-through to a mixer or exchange
- Mismatch between stated purpose and flow
- Wallet on or adjacent to the sanctions list
Why P2P gets flagged
P2P flows lack the intermediary controls of exchanges - the counterparty surface is direct. The screen is the compensating control.
The control
Screen the counterparty wallet and jurisdiction on every P2P payment; flag the patterns above; fail closed; log every decision.