Let's imagine a wholesale bank that has a medium money laundering risk customer in the business of manufacturing pharmaceuticals. The client relationship is 10 years old and the bank supports its client with a range of financing and payment products. The relationship manager sees a Wall Street Journal report alleging that the company secured the site on which its Mexican factory stands through bribes pay to provincial government officials. Is this negative news a material trigger which warrants a trigger review to be carried out? Yes, because it has the potential to change the customer's risk rating, or even to prevent the bank from continuing to provide service. An administrative trigger on the other hand, is one which has no material impact on the financial crime risk of the customer. Notification of a change of registered office address would be an administrative trigger for example. A material trigger has to be investigated, substantiated, and its effect upon the client risk evaluated. If the bank's investigations corroborate the negative news a possible outcome is denial of service to the client and ending of the relationship. Bribery and corruption is a predicate offense and financial service providers say they have zero tolerance for it.