The methodology for analysing suspicious activities is structured around four steps. The second step involves assessing the risk level by applying a documented classification that distinguishes between low, standard, and high-risk situations. This step is crucial for determining the appropriate due diligence measures.

Enhanced examination is provided for under Article L.561-10-2 of the Code monétaire et financier (CMF). This procedure applies to any particularly complex transaction, one involving an unusually high amount, or one with no apparent economic justification or lawful purpose. It requires the professional to investigate the origin and destination of funds, identify the financial means used, and document in writing all due diligence performed.

Enhanced examination requires the professional to document in writing all due diligence performed and to retain this documentation for five years. This requirement is crucial for ensuring traceability and compliance of the analyses conducted.

The analysis of suspicious activities relies on predefined criteria to methodically examine data. According to the text, these criteria include the client profile, the nature of the product or service requested, the characteristics of the transaction itself, and its geographical dimension. These elements help identify potential risk factors.

Warning indicators are divided into three main categories according to the ACPR-TRACFIN guidelines. Behavioural indicators relate to the client's attitude, transactional indicators focus on the transactions themselves, and structural indicators concern the client's legal structure. This categorisation is essential for identifying and analysing potential risks.

Suspicion is defined as a doubt leading the professional to question the regularity or lawfulness of a transaction. According to TRACFIN, this includes knowing, suspecting, or having reasonable grounds to suspect that the sums or transactions under review originate from an offence punishable by more than one year of imprisonment or are linked to terrorist financing. This definition excludes any automatism and requires an intellectual analysis based on objective and documented evidence.

Behavioural warning indicators relate to the client's attitude towards know-your-customer questions. According to the ACPR-TRACFIN guidelines of January 2025, a refusal to respond to KYC enquiries is an important warning signal. This may indicate an attempt at concealment or suspicious behaviour.

The text mentions a typical case illustrated in the TRACFIN brochure for notaries. It involves the acquisition of a property worth more than 500,000 euros by two foreign nationals with no declared occupation, whose fund calls are paid by third-party companies with no apparent connection to the buyers. This case illustrates a presumption of money laundering warranting a suspicious transaction report.