Moving money between shell companies, structuring transactions to avoid reporting, transferring funds to/from individuals on or associated with those on the SDN List, moving dollar amounts not in line with invoices or bills of lading, etc. I'm an AML Investigator when not writing superhero books.
Yesterday, UBS disclosed a record $145 million fine for failing to enforce AML policy which allowed nefarious dealings to happen on thier account platforms. AML is serious business. Capital One was simply following regulations. What was Eric doing that raised flags? What foreign money was he moving?