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Transactions showing structuring / layering indicators
| Date | Amount (£) | Counterparty | Channel | Branch | Notes |
|---|---|---|---|---|---|
| 2025-08-01 | 9,800 | FAZLI SUBHAN | Cash | London | Below threshold structuring |
| 2025-08-03 | 9,950 | Saeed Iqbal | Cash | Birmingham | Similar pattern |
| 2025-08-05 | 9,700 | Wajid Naeem | Cash | Manchester | Third-party trustee deposit |
| 2025-08-08 | 9,850 | FAZLI SUBHAN | Cash | Leeds | Repeating pattern |
| 2025-08-10 | 9,900 | Saeed Iqbal | Cash | London | Possible layering |
| 2025-08-12 | 10,000 | Wajid Naeem | Cash | London | Large cash deposit |
| 2025-08-16 | 120,000 | Nadeem Halal Meat Pvt Limited | Wire Transfer | London | Counterparty linked to trustee — outbound layering risk |
Red flags: trustee (Mir Ahmed) is director of Nadeem Halal Meat Pvt Limited; trustees are primary incoming funders instead of public donations — indicates layering.
Individual risk scoring (demo):
| Component | Score (0-100) | Comment |
|---|---|---|
| Customer Risk | 85 | Charity receiving trustee-originated funds; unusual. |
| Transaction Risk | 90 | Multiple near-threshold cash deposits and large wire transfer. |
| Geography Risk | 40 | Domestic activity but linked parties raise concern. |
| Behavioural Risk | 88 | Trustees funding and rapid outbound transfers indicate layering. |
Composite AI Risk Score: 85% — HIGH
Subject: PakhtunFoundation (Charity)
Prepared by: [Analyst]
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