The small client who changed, not the large one who didn’t.
A rule can compare this month’s outflows with the customer’s own twelve-month average, so a private client sending 2.4 times their usual amount stands out, and a trading company moving millions as normal does not.
Spotting structuring and layeringFlags the largest clients every month, whether anything changed or not.
Flags 418.230: outflows 2.4 × the usual, to a high-risk country.


