Free Checklist · KYC-Checks.nl

Recognise a risky professional adviser in 4 steps

Warning signs that a lawyer, accountant or trust service provider poses a risk to your business — and what you can do about it.

✅ 4 steps 📋 Printable ✍ KYC-Checks.nl

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🗣️ STEP 1  ·  Assess the adviser's behaviour
Does the adviser ask critical questions about the source of funds and the commercial rationale of the structure?
Is the adviser willing to have direct contact with the beneficial owner (UBO) — or does he actively avoid this?
Does the adviser communicate directly with you — or exclusively through intermediaries?
Is there no unusual time pressure? Urgency and artificial deadlines are a standard technique to prevent critical questions from being raised.
Does the adviser give clear answers to compliance questions — or does he avoid questions about risks and regulation?
Does the adviser refrain from minimising risks with phrases such as "everyone does this" or "this is fully legal" without further explanation?
A professional adviser has no objection to transparency. Evasive behaviour in response to compliance questions is itself a warning sign.
📄 STEP 2  ·  Assess the proposed structures and documents
Does the proposed structure have a demonstrable commercial justification — or does it exist solely to conceal ownership?
Does the adviser offer shelf companies that can be "delivered today", without the purpose being clear?
Does the adviser recommend complex international structures (holdings, offshore entities, trusts) without the underlying activities justifying this?
Do the contracts and documents reflect the economic reality — or do they describe a situation that does not correspond to what happens in practice?
Are there illogical financial flows — payments routed through countries with no clear connection, use of client accounts without explanation, or unusual invoicing structures?
Every structural layer without a discernible purpose increases your liability exposure — even if you personally derive no benefit from it.
💰 STEP 3  ·  Check the financial indicators
Is the source of funds flowing through the adviser verifiable and explicable?
Are there payments routed through countries without a demonstrable economic link to the transaction or the parties involved?
Is there no use of cash or cryptocurrency without a clear commercial rationale?
Do the invoices and amounts charged correspond to the scope and nature of the services provided?
Unexplained funding routed through an adviser is one of the strongest indicators of involvement in an enabler scheme.
🔍 STEP 4  ·  Investigate reputation and background
Is the adviser registered with the relevant professional body (Bar Association, ICAEW/ACCA, FCA/DNB register for trust firms) and are there no disciplinary findings?
Are there no adverse reports in news sources or trade publications about the adviser or firm?
Is the adviser not registered as director of dozens or hundreds of other entities? This is a classic indicator of a nominee arrangement without genuine involvement.
Is the adviser not based in a secrecy jurisdiction or high-risk country while providing services to European counterparties?
Is the adviser willing to share due diligence documentation about their own practice — client acceptance policy, AML procedures, UBO policy?
A quick OSINT check on name, firm and registration takes five minutes and can save you significant problems later.
💬 The question you must always ask: Is this adviser working for me — or primarily for their client, at the expense of my interests and in breach of the law? If you cannot answer that question with certainty, further investigation is required.

🚩 STOP — conduct further investigation if:

Concerned about an adviser or international structure?

Background investigations on professionals UBO analysis and sanctions screening Structure analysis
👉 Request a KYC report →

Bank-ready KYC report  ·  Within 48 hours  ·  Professional & independent