Which of the following is a red flag indicator for The Lawyer?

• A. Is at a significant distance from the client or transaction without a legitimate or economic reason
• B. Does not have experience in providing the particular services needed
• C. Is being paid substantially higher than usual fees without a legitimate reason
• D. Is frequently changed by the client or the client has multiple legal advisers without legitimate reason

Answer: (D)

In AML practice, a key red flag is when a client changes lawyers frequently or has multiple legal advisers without a legitimate reason. This pattern signals a potential attempt to obscure or fragment the paper trail, making it harder to establish a clear, continuous record of the client and the transaction. When a single, ongoing counsel relationship exists, the lawyer can build a coherent understanding of the client, the source of funds, and the purpose of the transaction. Frequent changes or many advisers can disrupt that understanding, create gaps in information, and raise questions about whether the client is trying to hide beneficial ownership, origins of funds, or potential conflicts of interest.

While other indicators—like being distant from the client or transaction, experience gaps, or unusually high fees—can also warrant scrutiny, they don’t as directly signal an attempt to evade oversight through shifting legal representation.