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Clear guidance on what "sufficient client checks" should be carried out would be helpful.

Hindsight is, as they say, is a wonderful thing, however there were a number of warning signs in both cases that if strung together might have made the alarm bells ring and might have prevented the frauds.

I have a list of 20 plus warning signs (red flags) that is freely available. If you would lie a copy please email me: rh@boldgroup.co.uk