AML Communication

A reply can be a tipping-off offence.

A report has been filed or an account is under review, and a colleague writes back to explain the delay: "between us, your account has been flagged." That sentence, not the report, is the offence. VerbaPulse flags the language that discloses an investigation before the message sends.

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The problem

The offence is in the sentence, not the suspicion

Tipping off is disclosing that a suspicious activity report has been made, or that a money laundering investigation is underway, in a way that could prejudice it. In the UK it is a criminal offence under POCA 2002 section 333A, and the EU anti-money laundering directives carry an equivalent prohibition. The act is the disclosure itself.

The MLRO knows the rules cold. The risk lives one desk over, with the relationship manager or the onboarding agent who is trying to be helpful. A frozen payment needs an explanation, a delayed onboarding needs a reason, and the honest answer ("we had to report this", "compliance is reviewing you") is the one that tips off. By the time supervision samples the mailbox, the message is already with the customer.

What it catches

The language that discloses an investigation

VerbaPulse reads the draft as it forms and flags the span that would disclose a review or report, with a plain reason. Real output from the product:

VerbaPulse High

"Compliance has opened a money laundering review on you, I wanted to give you a heads up."

Disclosing confidential investigation

Remove this disclosure before sendRemove

Here the safe move is removal, not a reword. VerbaPulse marks the exact span to delete while the message is still a draft.

The same check covers the quieter ways the disclosure slips out:

Naming a review, report, or investigation to the person who is its subject.
Explaining a freeze or delay in a way that points to a filed report ("we had to flag these transactions").
Secrecy framing that signals something is being hidden ("just between us", "do not repeat this").
Hints to move money quickly before something "escalates".
Your own rules: upload your financial crime communications policy and VerbaPulse enforces it on every draft.

How it works

In the inbox your team already uses

Install in minutes

The Outlook add-in deploys org-wide through the Microsoft 365 admin center, and the Chrome extension covers Gmail. No new tab, no change to how the team works.

Write as usual

As the reply forms, a disclosure span is flagged with severity and a plain reason, so the writer sees the risk in the sentence they just wrote.

Catch it before it sends

The risky line is removed while the message is still a draft. Anonymized events feed an audit trail your MLRO and compliance team can show.

Where this fits

A communication check, not an AML programme

VerbaPulse does not run KYC, transaction monitoring, or your SAR process, and it does not decide what is suspicious. Those belong to your AML framework and your MLRO. VerbaPulse sits at the one point they do not cover: the outbound message, where a careless explanation becomes the tipping-off act. It is one control inside email compliance for financial services, and it complements the monitoring and archiving systems you already run.

Email content is never stored: drafts are analyzed in memory and discarded immediately.
Nothing is used to train AI models.
The audit trail is anonymized by design: risk types, severities, and outcomes, never message text or named individuals.
It tells the difference between disclosing an investigation and discussing the rule, so an internal training email about tipping off does not get flagged as tipping off.

For the evidence behind this, our language risk benchmark runs real, anonymized cases through the product and reports what it flags.

FAQ

Common questions

What is tipping off in an AML context?

Tipping off is disclosing, to the subject or anyone else, that a suspicious activity report has been made or that a money laundering investigation is underway, in a way that could prejudice it. In the UK it is a criminal offence under POCA 2002 section 333A, and the EU anti-money laundering directives carry an equivalent prohibition. The risk usually comes from frontline staff explaining a delay or a freeze in plain language, not from the MLRO.

How does VerbaPulse help with tipping off?

It flags the language that does the tipping off: a reply that reveals a review or investigation, a hint at why a payment is frozen that points to a report, or a secrecy request like "just between us". VerbaPulse catches that span before the message sends and marks it for removal, while the wording can still change.

Does VerbaPulse decide what is suspicious or replace our AML monitoring?

No. It does not run KYC, transaction monitoring, or your SAR process, and it does not decide what is suspicious. Those stay with your AML framework and your MLRO. VerbaPulse only checks the outbound message for language that would disclose an investigation.

Is email content stored anywhere?

No. Drafts are analyzed in memory and discarded immediately. They are never stored and never used to train AI models. The audit trail keeps anonymized risk events (type, severity, action taken), never message text and never named individuals.