Immigrants from developing countries may not open bank accounts due to a number of factors including lack of identification documents and/or language barriers.  To assist immigrants send funds back to their families, a representative within their ethnic group will typically send funds overseas on their behalf. The representative may do so through the hawala system (underground banking) or by using their personal bank account.

Institutions should be vigilant for accounts being used to send regular low value funds, especially to the South Asia and Middle East regions. 

Such accounts may represent a customer who is acting as an informal money remitter and present further risks for the institution to manage.