Unexplained or unusual behaviour may include:

• Reluctance or refusal to provide identification, source-of-funds documentation, or required declarations
• Inconsistent or changing explanations about income, employment, or source of funds
• Sudden changes to the mortgage structure, lender choice, or transaction timing without a clear reason
• Allowing a third party to communicate instructions or make decisions on the client’s behalf without explanation
• Unusual urgency to complete a transaction or pressure to bypass standard procedures
• Discomfort, evasiveness, or objections when asked routine AML or compliance-related questions

When unexplained behaviour is identified, brokers and agents must apply enhanced due diligence by:

• Documenting the incident, including reasons for concern, client explanations or objections, and all related communications
• Escalating the matter to the compliance team for review and direction
• Retaining detailed file notes to support the risk assessment and any compliance decisions