top 10 financial crime risks · - example 1: a drug trafﬁcker purchases secondhand cars with cash...

Top 10 Financial Crime RisksThe most prevalent money laundering typologies whichthe financial services industry is exposed to in 2020

Top 10 Financial Crime Risks

Baringa is committed to reducingfinancial crime and the negativeconsequences it has on society. We helpour clients to better understand howfinancial crime is really carried out and toput in place targeted controls, enablingthem to become Compliant by Design.


Baringa has carried out a comprehensive study into the mostprevalent typologies for carrying out financial crime in thefinancial services industry. As a part of this study, an initial listof typologies was compiled. This list was:

p Based on our experience of working with investigations andintelligence teams in financial services as well as with lawenforcement and government bodies across the globe

p Corroborated using publicly available information fromgovernment and industry bodies, as well as high profilecases of money laundering in the media

This list was then shared with Financial Institutions (FIs) acrossthe globe in the form of a survey. Institutions were asked to:

1. Assess how often their organisation encounters eachtypology

2. Evaluate how effective their organisation is at mitigatingeach typology

3. Highlight any additional typologies which they haveencountered which were not on the initial list

This report describes the findings of the study and the surveyundertaken, with a particular focus on the ‘Top 10’ typologiesconsidered to pose the greatest risk to the financial servicesindustry. Please contact us for further details on the othertypologies or if you would like to discuss any of the content ofthis report in more detail.

Thank you to all organisations who participated – yourcontribution to these valuable industry insights is muchappreciated.

It is worth noting the following key points about this exercise:

p The list of typologies referred to in this report does notrepresent the full range of typologies used by criminals tolaunder money – our objective is to draw attention to themost prevalent typologies that need to be mitigated

p The focus of this report is primarily on money laundering,not terrorist financing, fraud or other types of financialcrime (these may be considered in future research)

p As this is Baringa’s inaugural financial crime risksbenchmark, we expect it to evolve over time as readershipand the number of participants increase

p Financial crime typologies could be presented atsignificantly different levels of granularity; the levelincluded here is intended to group typologies where thecharacteristics are broadly similar, even if they may beexecuted in slightly different ways. For example, whilst thefollowing two examples are different, they both involve theuse of high value assets to transfer value:

- Example 1: A drug trafficker purchases secondhand cars with cash and then sells them on to local car dealerships, enabling seemingly legitimate bank transfers into her account

- Example 2: A fraudster convinces vulnerable customers to transfer money into his bank account, uses the funds to purchase jewellery, and then sells it abroad in his home country

p Similarly, the typologies are presented independently ofthe predicate crimes that generated the illicit funds – in theexamples above, the fact the funds were generated usingdrug trafficking or fraud is considered inconsequential tothe means by which they were laundered

p The ranking of typologies is based on the survey responsesfrom institutions across the industry; these industriesprovide services to a wide variety of sectors, geographiesand customer types – as such, not all typologies will applyto all organisations

p The survey considers typologies which touch upon FIs only

p References to all third party sources used are provided inAppendix B of this document

Top 10 financial crimerisks research

1


Executive summaryTo be effective at preventing financial crime, andthe negative consequences it has on our society, wemust first establish consensus on the primary riskswe are attempting to mitigate.

2

Collectively across the financial services industry, a huge amount of time is spent on implementing and refining financial crimecontrol frameworks. Resources are prioritised according to a ‘risk-based approach’ by devising risk taxonomies, conductingenterprise wide risk assessments and directing attention towards the areas of the business with the greatest number of Ambersand Reds. However, these risk taxonomies tend to give a disproportionate amount of attention to regulatory requirements, andthe risk of not meeting them, rather than the means by which financial crime is actually carried out – that is, the financial crimetypologies the organisation is at risk of being exposed to.

This may be an appropriate way of prioritising a compliance programme but it is not the most effective way of preventingfinancial crime. No amount of culture programmes, gap analyses or machine learning algorithms will help to stop criminalsreaping the benefits of their illicit gains if their mechanisms for doing so are not understood.

This study is intended as an exposé of the most prevalent means for laundering money, to enable FIs to be more proactive inreducing financial crime and the negative consequences it has on society. It is intended to support you in reducing crime byproviding greater clarity about how criminals are exploiting your organisation.

The ‘Top 10’ most prevalent money laundering typologies1 encountered across the financial services industry in 2020, based onthe findings of this study, are as follows:


3

1 Typologies have been ranked according to the aggregate number of times they were encountered by survey respondents over a given time period.Participants were asked to rate how frequently they encountered a typology across the following categories; ‘Never (No known occurrences)’,‘Exceptionally (Less than annually)’, ‘Rarely (Annually or more)’, ‘Frequently (Quarterly to monthly)’, ‘Very frequently (Monthly or more)’. For thepurposes of simplifying the aggregation of the number of occurrences of each typology, it has been assumed that ‘less than annually’ means onceevery two years.

1Cash or quasi-cash deposits

(direct)

Top 10 Financial Crime Risks 2020

2Cash deposits through third

party 'channels'

3Use of 'mules' (complicit or

non-complicit)

4Use of money services

businesses (MSBs)

5Use of complex companystructures to conceal UBO

6Use of gambling outlets

7Direct cash deposits into another

individual or entity's account

8Structured cash deposits

9Control of another person to

deposit funds

10Use of high value assets to

transfer value


The Top 10

p Typologies involving cash deposits remain the mostprevalent despite changing trends in consumer behaviourto use less cash, suggesting that the cash economy isbeing buoyed by the illicit sector

p The controls in place across the industry are not consideredto be effective at mitigating any of the Top 10 risks,highlighting that there is still significant room forimprovement

p There appears to be a relatively weak correlation betweenthe prevalence of a risk and how effectively it is beingmitigated, which suggests the current approach tomitigating financial crime is not truly ‘risk-based’

p Many of the Top 10 typologies enable individuals who areunknown to an FI to place funds into that organisation,whether directly or via third party organisations; as long asFIs continue to permit channels which offer such a highdegree of anonymity, criminals will continue to exploitthem’

p Despite being rated the second most prevalent typology,controls for mitigating the abuse of cash deposits throughthird party ‘channels’ are weak, making it an attractiveoption for criminals

p The fact that the use of gambling outlets is the leasteffectively mitigated of the Top 10 may be symptomatic ofa more general challenge that FIs have in identifyingpotential money laundering which is one step removedfrom them, suggesting that much more targeted controlsneed to be put in place.

Beyond the Top 10

p Some of the less prevalent typologies – e.g. takeover offinancial systems and mirror trading – are relatively poorlymitigated but have a high business and customer impact,which should be taken into account when evaluating themagainst the organisation’s risk appetite

p Integration of illicit funds into licit cash intensive businessesis, perhaps surprisingly, one of the least frequentlyobserved typologies; given that such businesses are widelyconsidered as the epitome of money laundering, this mayimply that FIs are struggling to distinguish licit and illicitfunds flowing through such businesses

p Typologies relating to cryptocurrencies – cash depositsthrough bitcoin ATMs and significant use of cryptocurrency –are the least effectively mitigated, which may imply arecognition that in light of their increased presence moreneeds to be done to address them

4

Cash or quasi-cash deposits (direct)

Cash deposits through third party ‘channels’

Use of ‘mules’ (complicit or non-complicit)

Use of money services businesses (MSBs)

Use of complex company structures toconceal UBO

Use of gambling outlets

Direct cash deposits into another individual or entity’s account

Structured cash deposits

Control of another person to deposit funds

Use of high value assets to transfer value

Very ineffective Ineffective Neutral Effective Very effective

The average self-perceived level of effectiveness at mitigating each of these typologies across the industry is summarised below2:

Whilst the prevalence of some of these typologies will be very familiar, some interesting conclusions can be drawn from theresults:

2 Effectiveness has been measured here by averaging the level of effectiveness selected by each of the respondents for each typology. Participants were asked torate how effective they believe their organisation to be at preventing each typology by selecting one of the following options: ‘Very ineffective’, ‘Ineffective’,‘Neutral’, ‘Effective’ or ‘Very Effective’.


5

How Baringa can helpBaringa’s Financial Crime team are specialists in helping clients to identify their unique financial crime risks and implementingproportionate controls to detect and mitigate these risks. We have worked on the front line with both financial institutions andgovernment departments to reduce financial crime. Our deep financial crime knowledge, market insights and regulatoryexperience enables us to effectively support our clients in navigating the complex regulatory and criminal environments.Recognising that each financial institution has a unique business model, risk profile and risk appetite, we provide a tailoredapproach to each of our clients, whilst sharing insights into common industry challenges.

Please contact us for more information about the services we provide and how we can help your organisation. Our contactdetails can be found on the last page of this document.

LOAN

BUSINESS

BUSINESS

BUSINESS

BUSINESS

A-Z Financial Crime RisksEach risk forms a part of a complex network of criminal activity T


1


8


7

Use of ‘mules’(complicit or non-complicit)

3


9

Use of ‘shell accounts’to pool illicit funds


2

Use of informalremittance systems

(e.g. hawala or ‘backdoor MSBs’)


4

Significant use of cryptocurrency

POSTOFFICE

NAILSALON

Integration of illicit funds intolicit cash intensive businesses

Use of merchants toprocess illicit transactions

HAWALA

MSB

BUSINESS BUSINESS

International border

Appointment of ‘straw men’ into key company positions

Transfer of funds from a high crime / corruption environment to a low crime /

corruption environment

Default

Sell

Use of complex lending schemes

Mirror trading


Top 10 Financial Crime RisksEach risk forms a part of a complex network of criminal activity

6

Cash deposit (illicit)

Licit funds

Large cash deposit (illicit)

Control of

Financial transaction

Transfer of value

Bank account

Cryptocurrency exchange

Phishing attack

Loan agreementLOAN

LOAN

Legal entityENTITY

HIGH VALUE DEALER

BUSINESS

BUSINESS

BUSINESS

BUSINESSCASINO

Stocks

Fraudulent bill of lading

Computer network

Point of sale terminal

High value goods

Mule

Victim

Criminal

Innocent party

Politically Exposed Person

White horse

Top 10 financial crime

typology 0

Cash deposits throughBitcoin ATMs

Early repaymentof loans

HAWALA

MSB

BUSINESS BUSINESS

BUSINESS

BUSINESS

BUSINESSTRUST

border

Use of complex company structures to conceal ultimate beneficial owner (UBO)

5

CROWDFUND

Abuse of crowdfundingplatforms to pool funds

ATM

ATM

BUSINESS STATE

Use of senior public or corporate position to extricate misappropriated funds

Repay early

Sell property

KEY

Bank XYZ’s network

x10

Takeover of financial systems

Use of high value assetsto transfer value10

Use of gambling outlets6

Use of over-inflated orphantom trade shipments

Transfer of funds from a low crime / corruption environment to a high crime / corruption or low transparency environment

T

Buy

GuarantorU

Property

ATM

ATM

RefundCreditproduct Overpayment

Overpayment of credit products


7


Analysis

8


Survey respondentsRespondents were primarily based in the UK but responseswere also received from further afield across Europe, Asia,Africa and Australia. As the survey was open to institutionsacross the financial services industry, respondentorganisations offer a wide variety of services, including:

p Retailp Business Bankingp Corporate and Commercialp Private Bankingp Wholesale Bankingp Fund Managementp Insurancep Remittance

The primary lines of business offered by these organisationswas as follows:

Primary line of business

The majority of survey respondents (61%) work in the secondline of defence, whilst 34% work in the first line and 5% in thethird line. They work across the following functions:Compliance, SAR Investigations, Financial Intelligence Units,Operations, and Internal Audit. Whilst the line of defence isconsistent for some functions – Compliance (2nd), FIUs (2nd),and Internal Audit (3rd) – others sit in different lines ofdefences in different organisations – SAR Investigations(1st/2nd), and Operations (1st/2nd).

Respondent population by function

Retail22%

Universal17%

Corporate and Commercial

17%

Wholesale11%

Insurance11%

Remittance5%

Other17%

FinancialIntelligence Unit

14%

Operations34%

SARInvestigations

14%

Internal Audit5%

Compliance33%

9


Risk prevalenceFrequency of each typology

Industry participants were asked to rank how frequently they observed each of a series of typologies. The breakdown of theirresponses are summarised below:

10





Use of complex company structures to conceal UBO







Transfer from a low corruption environment to a high corruption environment

Transfer from a high crime environment to a low crime environment

Appointment of ‘straw men’ into key company positions

Use of informal remittance systems (e.g. hawala or 'backdoor MSBs')

Use of merchants to process illicit transactions

Early repayment of loans

Integration of illicit funds into licit cash intensive businesses

Use of ‘shell accounts’ to pool illicit funds

Cash deposits throiugh Bitcoin ATMs


Mirror trading


Use of over-inflated or phantom trade shipments


Abuse of crowd-funding platforms to pool funds

Very frequently (monthly or more)

Frequently (qurterly to monthly)

Rarely (annually or more)

Exceptionally (less than annually)

Never (no known occurrences)

0% 20% 40% 60% 80% 100%


Key observations:

p Typologies involving cash deposits remain the mostprevalent despite changing trends in consumerbehaviour: Some reports suggest that, despite the use ofcash being on the decline in the licit sector, overall cashusage is at least as high, if not higher, than it used to be asit is being buoyed by the illicit sector3. However, the UK’sNational Crime Agency (NCA) have observed an increase incash being moved from the UK overseas rather than beingdeposited locally, as FIs have become more aware of thistypology. This may suggest a greater imbalance in theprevalence of this typology in different jurisdictions goingforward, as jurisdictions which are enforcing increasinglystringent controls encourage this behaviour to take placeelsewhere.4

p Whilst direct cash deposits are the most common way oflaundering money, a greater number of FIs have beensubject to attempts to launder cash through third party‘channels’: Cash or quasi-cash deposits5 occurs mostfrequently overall but approximately 50% of organisationssaid that they come across cash deposits through thirdparty ‘channels’ either frequently or very frequently. This isconcerning considering more than 40% of institutions donot consider themselves to be effective at mitigating it.

p The vast majority (~90%) of organisations have comeacross attempts to launder money through the use ofcomplex company structures or by moving funds fromhigh crime environment to a low crime environment:Whilst the use of complex company structures to concealthe Ultimate Beneficial Owner only ranks fourth, andTransfer of funds from a high crime / corruption environmentto a low crime / corruption environment does not feature inthe Top 10, these typologies evidently occur widely, even ifnot as frequently as some others.

p The prevalence of the use of gambling outlets may bethe result of a lack of AML training in the gamblingsector: Whilst no respondents operate in the gamblingsector directly, FIs have clearly observed money beinglaundered through this channel. The U.K. GamblingCommission6 recently highlighted that gambling operatorsare failing to provide training on how to deal withtransactions which may be indicative of money laundering– this may help to explain the frequency with which FIs arecoming across this typology.

Least frequently observed typologies

The least prevalent typologies, according to industryrespondents, are ranked below, ordered by the least prevalent first:

Typology





Mirror trading


Cash deposits through Bitcoin ATMs

Use of 'shell accounts' to pool illicit funds

Integration of illicit funds into licit cash intensive businesses


Rank

1

2

3

4

5

6

7

8

9

10

Key observations:

p The majority (~65%) of respondents indicated that theyhad never witnessed an attempt to takeover financialsystems to launder money – however, given the highimpact of this typology, and the ubiquitous nature ofcybercrime, it is important financial crime teamsunderstand the nature of this threat: The moneylaundering elements of serious cyber or fraud events in FIscan sometimes be overlooked given how intertwined theycan be with other elements of these crimes. Yet, they are akey enabler to the crimes being successful and so it isimportant that they are considered as a part of the controlsbeing in place to prevent such incidents. For example,effective monitoring of funds being pooled in internalaccounts or transferred to common external accounts overa short period of time could help to mitigate incidents likethe Carbanak case, which affected 100 FIs across 40countries.7

11

3 For example: ‘Why is cash still king? A strategic report on the use of cash by criminal groups as a facilitator for money laundering’, Europol,https://www.europol.europa.eu/publications-documents/why-cash-still-king-strategic-report-use-of-cash-criminal-groups-facilitator-for-money-laundering;‘Will cash die out?’, Bank of England, https://www.bankofengland.co.uk/knowledgebank/will-cash-die-out

4 ‘National Strategic Assessment of Serious and Organised Crime’, National Crime Agency, https://nationalcrimeagency.gov.uk/who-we-are/publications/296-national-strategic-assessment-of-serious-organised-crime-2019/file

5 Quasi-cash comprises bearer instruments which enable the transfer of value in a similar way to cash – e.g. traveller’s cheques6 Enforcement report 2018/19, U.K. Gambling Commission, https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/General-

compliance/Enforcement-report-2019/Enforcement-report-201819-Anti-money-laundering.aspx7 ‘Mastermind behind EUR 1 Billion Cyber Bank Robbery Arrested In Spain’, Europol, https://www.europol.europa.eu/newsroom/news/mastermind-behind-eur-1-

billion-cyber-bank-robbery-arrested-in-spain


p Integration of illicit funds into licit cash intensivebusinesses is, perhaps surprisingly, one of the leastfrequently observed typologies: Given that cash intensivebusinesses are widely considered as the epitome of moneylaundering8, this may indicate that FIs do not currentlyhave the tools available to them to identify anddifferentiate licit and illicit cash flows amongst suchbusinesses. This may lead to it being an ongoing preferredmethod of laundering money.

p Whilst early repayment of loans is often cited as acommon money laundering typology, it does not featurein the Top 10: It does, however, feature within the Top 10for Corporate and Commercial and Wholesale Banking,which implies it is more specific to these lines of businessand not frequently employed more broadly.

p Some of the rest of these typologies may also beobserved less frequently overall because they arespecific to particular lines of business: For example,mirror trading was not observed very frequently overall butfeatures in the Top 10 for Wholesale Banking. Similarly,limited representation from respondents involved in Trademay explain the infrequency of the use of over-inflated orphantom trade shipments typology.

Frequency of typologies by Line of Business

The most prevalent typologies for Retail, Commercial andCorporate, and Wholesale are included below.

Retail

Whilst the Top 10 within Retail is broadly similar to the overallTop 10, it is interesting to note that:

p ‘Mules’ continue to be a preferred means for launderingmoney, particularly in Retail Banking: The use of ‘mules’(complicit or non-complicit) is the third most frequenttypology overall, and the most frequent typology in RetailBanking. This is aligned with recent reports from the NCAand Europol9. Mules are typically recruited online,knowingly or unknowingly, and used to launder theproceeds of cyberattacks and online fraud.

Typology

Use of 'mules' (complicit or non-complicit)






Direct cash deposits into another individual or entity's account

Cash deposits through third party 'channels'



Rank

1

2

3

4

5

6

7

8

9

10

12

8 ‘National Strategic Assessment of Serious and Organised Crime’, NCA, https://www.nationalcrimeagency.gov.uk/who-we-are/publications/173-national-strategic-assessment-of-serious-and-organised-crime-2018/file

9 ‘228 Arrests And Over 3800 Money Mules Identified in Global Action Against Money Laundering’, Europol, https://www.europol.europa.eu/newsroom/news/228-arrests-and-over-3800-money-mules-identified-in-global-action-against-money-laundering; ‘National Strategic Assessment of Serious and Organised Crime’,NCA, https://www.nationalcrimeagency.gov.uk/who-we-are/publications/173-national-strategic-assessment-of-serious-and-organised-crime-2018/file; ‘FromMoney Mules to Chain-Hopping’, RUSI, https://rusi.org/sites/default/files/20181129_from_money_mules_to_chain-hopping_web.pdf


Wholesale

Typology


Direct cash deposits into another individual or entity's account









Rank

1

2

3

4

5

6

7

8

9

10

As might be expected, the use of complex company structuresto conceal the Ultimate Beneficial Owner as means oflaundering money is more common within the Corporate andCommercial sector than within Retail. Perhaps slightly moresignificantly:

p The use of merchants to process illicit transactions tolaunder money is prevalent within the Corporate andCommercial sector: As this is one of the least effectivelymitigated typologies, it is important that more is done toaddress it within this line of business. Criminals use point-of-sale transactions as means of transferring illicit funds orfor the purchase of illicit goods. The merchant involvedmay or may not be complicit. For example, books werebeing sold on Amazon for a very high purchase value whichappeared to contain nothing more than a computer-generated story.10

p The expansion of the regulated sector to include the artmarket under the EU’s 5th Money Laundering Directiveshould help to mitigate some of the risk associated withhigh value goods in this sector: Whilst FIs will need tocontinue to be vigilant of transactions in the art market(and other high value goods markets), such legislationshould compress the use of high value assets to transfervalue to launder money, if it is implemented effectively.

Typology



Appointment of 'straw men' into key company positions


Mirror trading






Rank

1

2

3

4

5

6

7

8

9

10

Wholesale typologies, predictably, are less cash-focused andhave a greater emphasis on corporate ownership structuresand vehicles. Of particular note:

p The use of complex lending schemes is the second mostprevalent typology in Wholesale Banking: This typologyoften involves loans being made from one company toanother in order to facilitate the movement of funds, whilstobfuscating their origin. It was employed by the GlobalLaundromat in order to facilitate the movement of fundsfrom Russia into the EU.11

p The prevalence of mirror trading as a means to clean theproceeds of crime has become renowned across thefinancial services industry following the high profile case atDeutsche Bank12 and broader concerns from regulatorsabout the prevalence of money laundering in the capitalmarkets industry, most notably in the form of the 2019thematic review from the UK’s FCA.13

p The inclusion of use of gambling outlets here may be an anomaly, potentially as a result of secondary lines of business the particular FIs happen to offer.

Corporate and Commercial

13

10 ‘Fake books sold on Amazon could be used for money laundering’, The Guardian, https://www.theguardian.com/books/2018/apr/27/fake-books-sold-amazon-money-laundering

11 ‘The Russian Laundromat’, OCCRP, https://www.reportingproject.net/therussianlaundromat/russian-laundromat.php12 ‘FCA fines Deutsche Bank £163 million for serious anti-money laundering controls failings’, FCA, https://www.fca.org.uk/news/press-releases/fca-fines-

deutsche-bank-163-million-anti-money-laundering-controls-failure13 ‘Understanding the money laundering risks in the capital markets’, FCA, https://www.fca.org.uk/publications/thematic-reviews/tr19-4-understanding-

money-laundering-risks-capital-markets


Risk mitigationMitigation of the Top 10

Industry participants were also asked to comment on how effective they considered their institution to be at mitigating eachtypology. The results were then compared to the Top 10 most prevalent typologies to determine how effective organisations’controls are relative to their risk exposure.

Key observations:

p The controls in place across the industry are notconsidered to be effective at mitigating any of the Top10 risks: In fact, less than 65% of organisations considerthemselves to be mitigating at least 50% of thesetypologies effectively. There is clearly more to be done toensure FIs are equipped to mitigate the most commonways of laundering money.

p There appears to be a relatively weak correlationbetween the prevalence of a risk and how effectively itis being mitigated, which suggests the current approachto mitigating financial crime is not truly ‘risk-based’:Whilst some typologies appear to be mitigated relativelywell across the industry (e.g. the transfer of funds to andfrom high risk jurisdictions), they fall outside of the Top 10.At the same time, there are typologies within the Top 10which are, on average, mitigated less effectively.

p Despite being rated the second most prevalenttypology, controls for mitigating the abuse of cashdeposits through third party ‘channels’ are weak: Morethan 40% of respondents do not consider themselves to beeffective at mitigating the misuse of deposits through thirdparty ‘channels’ such as non-bank ATM networks and postoffices. By way of an example, in 2018, £700k waslaundered into the financial services network through apost office that was no longer in use.14

p Use of complex company structures to conceal UBOs isconsidered to be the most effectively mitigatedtypology in the Top 10, with 82% of respondentsconsidering their controls for this typology to be‘Effective’ or ‘Very Effective’: Increased scrutiny aroundbeneficial ownership following on from some high profilescandals – e.g. the Panama Papers and the Troika

14

14 ‘Four jailed over £700,000 fraud after Post Office didn't realise a branch had closed’, ITV News, https://www.itv.com/news/meridian/2018-04-29/four-jailed-over-700-000-fraud-after-post-office-didnt-realise-a-branch-had-closed/





Use of complex company structures toconceal UBO






Very ineffective Ineffective Neutral Effective Very effective


Least effectively mitigated typologies

The least effectively mitigated typologies, according toindustry respondents, are ranked below, least effectivelymitigated first:

Laundromat – may help explain more robust controls beingput in place to mitigate this typology. Despite this, the useof complex company structures continues to presentchallenges when trying to identify a customer’s UBO,evidenced by the ongoing prevalence of the typology.Organisations should invest in high quality data sources asa part of Customer Due Diligence (CDD) processes to helpthem to unpick complex ownership structures and identifyUBOs. Organisations should also closely follow thegovernment’s planned reform15 of the Companies Houseregister that aims to enhance data quality of the U.K.’sregister, including information on directors and people withsignificant control (PSCs).

p The fact that the use of gambling outlets is the leasteffectively mitigated of the Top 10 may be symptomaticof a more general challenge that FIs have in identifyingpotential money laundering which is one step removedfrom them: FIs are often only exposed to electronictransactions with gambling outlets or crypto exchanges,rather than the predicate behaviour, which may be moreeasily identifiable and more obviously nefarious.16

However, more targeted controls can help to identifycustomers who have substantial activity with gamblingoutlets or cryptocurrencies, and to identify patterns whichmay be indicative of nefarious behaviour.

p Some typologies which can have a high business andcustomer impact – e.g. takeover of financial systems andmirror trading – are considered to be among the leastprevalent and are relatively poorly mitigated: Whilst thelow occurrence of such typologies may explain the reducedfocus on implementing more effective controls, it isimportant that FIs consider the impact of a breach of acontrol, in addition to likelihood, to mitigate against ‘blackswan’ events. For example, when hackers took over aSWIFT terminal at Bangladesh’s central bank, they wereable to launder $81 million stolen from the bank.17

Typology

Cash deposits through Bitcoin ATMs




Appointment of 'straw men' into key company positions






Rank

1

2

3

4

5

6

7

8

9

10

Key observations:

p Many of the typologies considered to be leasteffectively mitigated are those which are mosteffectively subsumed into the licit sector: As highlightedabove, more targeted approaches are required to deal withtypologies such as gambling outlets where the predicatebehaviour is not readily available to FIs. Similarly, each ofthe following present significant challenges for FIs, as theyare not readily differentiated from licit behaviour:

- Processing of business transactions which are the proceeds of Bitcoin ATM deposits (cash deposits through Bitcoin ATMs)

- Processing seemingly legitimate merchant transactions (use of merchants to process illicit transactions)

- Processing seemingly legitimate transactions involving crowd-funding websites (abuse of crowd-funding platforms to pool funds)

- Carrying out transactions on behalf of known directors who have been appointed in place of the real UBOs (appointment of 'straw men' into key company positions)

Whilst these typologies may present a challenge toidentify, FIs must establish more effective ways ofmitigating them – particularly those which have beenidentified as more prevalent – otherwise, these will quicklybecome the preferred methods for laundering money.

15

15 ‘How we’re reforming the Companies House register’, Companies House, https://companieshouse.blog.gov.uk/2019/06/11/how-were-reforming-the-companies-house-register/

16 Whilst recent efforts from the UK Gambling Commission seek to improve AML compliance across the gambling industry, it is important FIs become moreeffective at mitigating this risk, given the relative lack of control that has been in place. See also ‘Enforcement report 2018/19’, UK Gambling Commission,https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/General-compliance/Enforcement-report-2019/Enforcement-report-201819-Anti-money-laundering.aspx

17 ‘Bangladesh Bank official computer was hacked to carry out $81 million heist’, Reuters, https://uk.reuters.com/article/us-cyber-heist-philippines/bangladesh-bank-officials-computer-was-hacked-to-carry-out-81-million-heist-diplomat-idUKKCN0YA0CH


- Investing in high quality data sources as an input to CDD in order to unpick complex ownership structures and identify UBOs. Organisations should also closely follow the UK government’s planned reform of the Companies House register that aims to enhance its data quality, including information on directors and people with significant control (PSCs).

p Building a comprehensive understanding of theexpected behaviour of a customer, through their initialKYC and ongoing relationship, to enable identification ofbehaviour that is out of the norm. This will help to identifycustomers who start to, knowingly or unknowingly,facilitate financial crime – e.g. as in the use of ‘mules’typology.

p Recognising simple manual controls, implementedthrough robust training and procedures, are still criticalto preventing financial crime, such as identifyingcustomers who come into a high street branch who may beunder another person’s control. This will help to mitigatecontrol of another person to deposit funds.

p Innovating to identify patterns of behaviour which maybe indicative of financial crime, even where thepredicate behaviour is not readily available; sometypologies – e.g. use of gambling outlets, significant use ofcryptocurrency, and integration of illicit funds into licit cashintensive businesses – will require more targetedapproaches to identify customers engaging in nefariousbehaviour.

p Being proactive in identifying typologies that present arisk to your organisation and tailoring controls toensure that they are being detected and mitigatedeffectively. This may include:

- Performing horizon scanning on a regular basis to identify emerging typologies which may impact your organisation - e.g. by reviewing regulatory reports, publicly available case studies and SARs that your organisation has raised.

- Undertaking ‘campaigns’ within your organisation to proactively identify how a particular typology is manifesting within different business areas, and designing targeted controls to mitigate it.

Improving preventionThe research carried out, summarised in this report, isintended to provide a clearer understanding of the mostprevalent typologies for laundering money and how effectivelythey are currently being mitigated across the industry. It hasidentified that there is a relatively weak correlation betweenthe typologies FIs are at risk of being exposed to and thecontrols in place to mitigate them. This highlights a need forthe industry to better understand how financial crime iscarried out and put greater emphasis on taking a risk-basedapproach to reducing financial crime. That is, an approachwhich is truly focused on the financial crime risks FIs areexposed to, not just the risk of non-compliance.

There are some practical steps that FIs can take to strengthentheir financial crime controls in response to the findings of thisresearch:

p Reducing opportunities for anonymity, including:

- Requiring that third party organisations have at least equivalent ID&V controls in place for depositors and that this information is made available to their organisation for monitoring – this will help to mitigate the risk of cash deposits through third party ‘channels’.

- Prohibiting third party cash deposits, or requiring that appropriate identification is provided by third parties and logged for ongoing monitoring, so that mules or individuals paying for criminal services cannot make deposits anonymously. Whilst a number of FIs already prohibit cash deposits into customer accounts by third parties, this does not appear to be the case industrywide. This will help to mitigate the use of ‘mules’ and direct cash deposits into another individual or entity's account.

- Requiring complete originator and beneficiary information to be included on all transactions, including those carried out through MSBs or other downstream providers, to reduce the risk associated with the use of MSBs. Without this information, it is virtually impossible to establish profiles of counterparties and understand whether or not their behaviour is unusual. This is also required under the Funds Transfer Regulation, in response to FATF Recommendation 16.18

16

18 ‘Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealingRegulation (EC) No 1781/2006’, Official Journal of the European Union, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015R0847


17


18

Appendices

Appendix A: Top 10 risks explainedThe table below explains each of the Top 10 risks, associated ‘red flags’, and provides real-life examples of the typology beingcarried out.


TypologyMoney launderingtypology

Cash or quasi-cashdeposits (direct)

Cash depositsthrough third party‘channels’

Typology descriptionExplanation of the typology

Large amounts of cash aredeposited into an account.Alternatively, quasi-cashinstruments such astravellers’ cheques are usedto make deposits.

Criminals continue to usecash and quasi-cashinstruments because, as‘bearer negotiableinstruments’, their valuebelongs to the person whoholds them. This makes itdifficult to ascertain theultimate source orbeneficiary of that value.

Third party ‘channels’ areused to deposit cash - e.g.non-bank ATM networks andpost offices. Such channelsprovide a greater level oranonymity as they enableless direct contact with theissuer of the account andmay have weaker moneylaundering controls.

Red flagsWarning signs that may indicate thatthe typology is being carried out

p The majority, if not all, of thedeposits made into the accountare made in cash or quasi-cash

p The total cash or quasi-cashdeposits on the account aresignificantly higher thancustomers of a similar type (e.g.Retail customers with a similarincome, or Corporate customerswith a similar revenue)

p Deposits are of a ‘round’ amount(e.g. £1,000)

p There is a sudden andunexplained increase in cash orquasi-cash deposits

p Total value of cash deposits over ashort period is large

p Multiple deposits are made withina single day

p Deposits are made through adisparate range

ExamplesExample of the typology being carriedout

A recent fine against StandardChartered Bank from the FCAhighlighted that an individual wasable to open an account in the UAEwith 3 million (AED) in cash, whichhad been brought into the branch in asuitcase. See FCA Decision Notice.

HSBC were found to have cashed$290m (USD) of travellers’ chequesover a four year period on behalf of aJapanese bank. The cheques werereceived in large blocks and weresequentially number. These werecashed on behalf of Japanese clientsof the bank, purporting to be in theused car business, but had originallybeen purchased by Russian nationals.See US Senate Report ‘U.S.Vulnerabilities to Money Laundering,Drugs, and Terrorist Financing:HSBC Case History’.

In 2018, Commonwealth Bank ofAustralia (CBA) agreed to pay a$700m (AUD) fine for failings in itscontrols relating to ATM deposits.Although these ATMs were within itsdirect control and not part of a thirdparty network, this case highlightschallenges with cash deposits throughchannels which do not require face-to-face interaction. CBA’s ATMspermitted anonymous cash depositsof up to $20k (AUD) per transaction.Additionally, there was no limit on thenumber of the transactions that couldbe carried out per account in one day.This enabled criminals to launderlarge amounts of money through thebank - for example, a group of 3 menlaundered $4.5m (AUD) in the spaceof five weeks. See AUSTRAC article‘AUSTRAC and CBA agree $700mpenalty’.

RankRiskrank

1

2

19



Use of ‘mules’(complicit or non-complicit)

Use of moneyservices businesses(MSBs)

Use of complexcorporatestructures toconceal ultimatebeneficial owner(UBO)


Third party individuals’accounts are used, eitherknowingly or unknowingly,to process illicit funds. Fundsare often deposited usingcash, electronic transfer orcheques. The funds are thentransferred from the mules’account into anotheraccount, legitimising thesource of funds.

MSBs, such as remittanceproviders, often have weakeridentification andverification controls in place,which provides a greaterlevel of anonymity andmakes it easier to concealthe source and/ordestination of funds.Customers may use theseservices as a means to placecash or cheques into thefinancial system, to poolfunds abroad or to pay forillicit services.

Corporate structures are setup using a variety ofcorporate vehicles andmultiple layers of ownership,often across severaljurisdictions, in order toobscure the ultimatecontroller and beneficiary ofthe corporation’s activities.


p Relatively large deposits madeinto student or young persons’accounts via cash or wire transfer

p Deposit values are inconsistentwith customer’s prior accountactivity

p A debit or a similar value, oftenwith a ‘processing fee’ deducted,is made within a few days of thedeposit

p Customer is unable to provide aclear explanation of the source offunds

For customers utilising MSBs:

p Frequent usage of MSBs withlimited other activity on theaccount

For MSB accounts:

p Structured transactions involvingthe same geographic areas (evenif carried out by differentcustomers)

p Multiple transactions between thesame originator and beneficiaryover a short period of time

p Lack of ultimate originator and/orultimate beneficiary information(and the jurisdictions in whichthey reside) on transactionsprocessed through the MSB’saccount

p Corporate structures have a levelof complexity that does not makesense for the nature business (e.g.use of trusts, Scottishpartnerships, holding companies)

p Involvement of low-tax or low-transparency jurisdictions in theownership structure

p Activities carried out on thecorporation’s accounts do notreflect those of a legitimatebusiness or are inconsistent withits nature of business

p Transactions are made withforeign jurisdictions which have noapparent connection to thecorporation


Gardaí in Ireland announced that theywere investigating approximately 200accounts that they believe to havebeen used by mules to depositmillions of euros. The funds weredeposited in amounts of £5000 to£35,000 (GBP). See Irish Times article‘Gardaí investigating €2 million‘money mule’ laundering racket’.

An FIU identified a series of unusualtransactions made via a moneyremitter to South America. Thetransactions had been instructed by anumber of different people throughseveral branches of the remitterlocated within the same area of thecountry. Despite the majority of theindividuals instructing thetransactions having no prior criminalrecord, one was found to have aconnection to a large drug traffickingorganisation and it is likely that thebeneficiaries of these transactionswere involved in the sameorganisation. See ‘Remittances to highrisk countries’ case study in FATFreport ‘Money Laundering throughMoney Remittance and CurrencyExchange Providers’, page 27.

An Australian drug traffickingorganisation set up a transportcompany and used it to deposit fundsgenerated through cannabis sales.They then transferred funds to alegitimate wage processing companywho paid salaries of approx. S100k(AUD) to the criminal members of theorganisation. See ‘Case study 2’ inFATF report ‘Concealment of BeneficialOwnership’.

A recent Global Witness report(‘Getting the UK’s House In Order’)suggests:

p 336,224 companies in the UK statethat they have no beneficial owner

p 6,711 are controlled by beneficialowners who control more than 100companies (likely to be nominees)

p 487 have circular ownershipsstructures, implying they controlthemselves

RankRiskrank

3

4

5

20



Use of gamblingoutlets

Direct cashdeposits intoanother individualor entity’s account

Structured cashdeposits


Criminal funds are depositedat gambling outlets – e.g. abetting shop or casino – andused to place bets on eventswhich are very likely tooccur. Winnings are thenredeemed and paid into abank account as seeminglylegitimate funds.

Cash is deposited into anindividual or entity’s accountby a third party (who has notundergone identity andverification checks on theaccount) to obfuscate theidentity of the depositor.

Control of the account mayhave been unofficiallygranted to the third party bythe named account holderor the account may havebeen set up using falsifieddocumentation.

Cash is deposited into anaccount in a series of smalltransactions to attempt toevade detection.


p Customer receives high valuedeposits into their account fromgambling outlets

p Customer provides gamblingreceipts as evidence for cashdeposits

p Individual depositing the funds isunwilling to provide anexplanation for the source offunds

p The funds are subsequentlytransferred to another account

p A large number of smallerdeposits are made on the account

p Deposits are made a long distancefrom where the account wasoriginally opened and/or theaddress registered on the account

p Deposits are made from disparatelocations

p The total cash deposits on theaccount are significantly higherthan customers of a similar type(e.g. Retail customers with asimilar income, or Corporatecustomers with a similar revenue)

p Where a local ‘reporting threshold’is in place, deposits made are veryclose to this value

p Value of transfers out of theaccount are significantly higherthan the value of the individualdeposits


In an example sometimes referred toas the ‘Vancouver model’, a hawala-style network was used to move thevalue of Chinese money out of Chinato avoid capital controls, whilst alsoenabling the laundering of drugmoney in Canada. Wealthy Chinesecitizens sent their money to aspecified account within China. Theythen travelled to Canada where fundswere delivered to them in cash(Canadian dollars). They launderedthis money through casinos bypurchasing chips and then cashingthem out as clean money. See ‘DirtyMoney’ report commissioned by theAttorney General of British Colombia.

In the US, some banks restricted thirdparty cash deposits on accountsfollowing a FinCEN advisory noticeabout their misuse. For example, in2013, 13 individuals based inCalifornia were prosecuted for illegallyselling prescription drugs across theUS, often delivered by mail. More than$3.5m (USD) in cash was depositeddirectly into their accounts by thepurchasers of the drugs in branchesall over the US. See US Department ofthe Treasury ‘National MoneyLaundering Risk Assessment 2015’.

The owner and sole director of a retailcompany made multiple cashdeposits below the reportingthreshold in Australia over a period offive years, totalling more than $2.5million (AUD). The proceeds weredeposited into the company accountbefore being transferred to theindividual’s personal account. SeeAUSTRAC article ‘Offender convictedof structuring funds to laundermoney: $1 million recovered’.

.

RankRiskrank

6

7

8

21



Control of anotherperson to depositfunds

Use of high valueassets to transfervalue


Funds are deposited orredeemed - e.g. by cashing acheque - by an individualwho is being controlled bysomeone else (a ‘handler’).

This typology is a commontrait of human trafficking.

Funds obtained from illicitactivity is used to purchasehigh value goods, such asjewellery, art, second-handcars, heavy machinery andconstruction equipment.These assets are then sold inorder to transfer value with aseemingly legitimate source.This may form part of atrade-based moneylaundering scheme, wherethe goods are shipped toanother country and thensold to release the funds inthat country.


p The handler may be present inbranch to translate, answerquestions, provide ID and controlthe individual depositing orredeeming the funds

p Funds being deposited orredeemed are of a ‘round’ amount(e.g. £1,000)

p The customer has a ‘basic’ orstudent bank account but asignificant amount of funds arebeing deposited (Note: A ‘basic’bank account is one which hasmore limited facilities - e.g. nooverdraft - but has less stringenteligibility criteria - e.g. individualswith lower credit scores arepermitted to open them).

p Account activity is primarily cash-based

p High value purchases from luxuryretailers, car dealers orconstruction that are of a size, orfrequency, that is atypical forcustomers with a similar profile

p Frequent payments to shippingand logistics firms, that areatypical for customers with asimilar profile


A female customer was regularlyentering a branch to deposit cashthrough an ATM. She wasaccompanied by a male who seemedto be demonstrating coercivebehaviours over her (e.g. checkingstatements and deposits). See FATFreport ‘Financial Flows from HumanTrafficking’, page 22.

A group of individuals in Dallas, USwere involved in a fraudulent taxrefund scheme. They used ~$1.2m(USD) acquired from this scheme topurchase 204 used cars which theyexported to Nigeria. See USImmigration and CustomsEnforcement article ‘Federal juryconvicts Dallas woman in stolenidentity refund scheme; some stolenidentities belonged to incarceratedindividuals’.

An Iraqi crime syndicate used cashcouriers, who travelled by car acrossEurope, to collect the proceeds fromthe sale of heroin. Funds were thentransferred to the Middle East throughthe shipment of assets such assecond-hand cars, machinery andconstruction equipment that werepurchased in Germany and exchangedfor clean cash once in Iraq. See‘Operation Kandil’ in FATF report‘Professional Money Laundering’, page22.

RankRiskrank

9

10

22

Appendix B: Typology References


Typology

Cash or quasi-cashdeposits (direct)

Cash depositsthrough third party‘channels’

Use of 'mules'(complicit or non-complicit)

Use of moneyservices businesses(MSBs)

Use of complexcompany structuresto conceal UBO

Use of gamblingoutlets

Direct cash depositsinto anotherindividual or entity'saccount

Structured cashdeposits

Control of anotherperson to depositfunds

Use of high valueassets to transfervalue

Reference

p Decision Note: Standard Chartered Bank, FCA, https://www.fca.org.uk/publication/decision-notices/standard-chartered-bank-2019.pdf

p ‘U.S. Vulnerabilities to Money Laundering, Drugs, and Terrorist Financing: HSBC Case History’, US Senate,https://www.hsgac.senate.gov/imo/media/doc/PSI%20REPORT-HSBC%20CASE%20HISTORY%20(9.6).pdf

p ‘AUSTRAC and CBA agree $700m penalty’, AUSTRAC, http://www.austrac.gov.au/media/media-releases/austrac-and-cba-agree-700m-penalty

p ‘CBA money laundering allegations: How three men got away with it’, ABC News, https://www.abc.net.au/news/2017-08-03/cba-money-laundering-law-breach-claim-how-men-got-away-with-it/8771652

p ‘Gardaí investigating €2 million ‘money mule’ laundering racket’, Irish Times, https://www.irishtimes.com/news/crime-and-law/garda%C3%AD-investigating-2-million-money-mule-laundering-racket-1.3855576

p Fraudscape 2018, CIFAS, https://www.cifas.org.uk/insight/reports-trends/fraudscape-report-2018

p ‘Money service business guidance for money laundering supervision’, HM Revenue & Customs,https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/686152/Money_Service_Businesses_Guidance.pdf

p ‘Money Service Businesses’, JMLSG, https://secureservercdn.net/160.153.138.163/a3a.8f7.myftpupload.com/wp-content/uploads/2019/09/Part_II_Nov_14_1.pdf

p ‘Money Laundering through Money Remittance and Currency Exchange Providers’, FATF, http://www.fatf-gafi.org/media/fatf/ML%20through%20Remittance%20and%20Currency%20Exchange%20Providers.pdf

p ‘Money Service Businesses in the UK: Improving the Conditions for Effective Financial Crime Supervision and Investigations’,Royal United Services Institute (RUSI),https://rusi.org/sites/default/files/201801_rusi_money_service_businesses_in_the_uk_kraft_web.pdf

p ‘Concealment of Beneficial Ownership’, FATF, http://www.fatf-gafi.org/media/fatf/documents/reports/FATF-Egmont-Concealment-beneficial-ownership.pdf

p ‘Getting the UK’s House In Order’, Global Witness, https://www.globalwitness.org/en-gb/blog/uk-governments-no-questions-asked-approach-to-companies/

p ‘Dirty Money: An Independent Review of Money Laundering in Lower Mainland Casinos conducted for the Attorney General ofBritish Columbia’, Peter German & Associates Inc., https://news.gov.bc.ca/files/Gaming_Final_Report.pdf

p ‘How criminals used Canada’s casinos to launder millions’, The Guardian,https://www.theguardian.com/world/2018/oct/15/canada-money-laundering-casino-vancouver-model

p ‘Vulnerabilities of Casinos and Gaming Sector’, FATF, http://www.fatf-gafi.org/media/fatf/documents/reports/Vulnerabilities%20of%20Casinos%20and%20Gaming%20Sector.pdf

p ‘Update on U.S. Currency Restrictions in Mexico: Funnel Accounts and TBML’, FinCEN,https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2014-a005

p ‘National Money Laundering Risk Assessment 2015’, US Department of the Treasury, https://www.treasury.gov/resource-center/terrorist-illicit-finance/Documents/National%20Money%20Laundering%20Risk%20Assessment%20%E2%80%93%2006-12-2015.pdf

p US Immigrations and Customs Office, Cornerstone Report, Vol 11: No. 1,https://www.ice.gov/sites/default/files/documents/Report/2015/cornerstone11-1.pdf

p ‘Why is cash still king? A strategic report on the use of cash by criminal groups as a facilitator for money laundering’, Europol,https://www.europol.europa.eu/publications-documents/why-cash-still-king-strategic-report-use-of-cash-criminal-groups-facilitator-for-money-laundering

p ‘Offender convicted of structuring funds to launder money: $1 million recovered’, AUSTRAC, http://www.austrac.gov.au/case-studies/offender-convicted-structuring-funds-launder-money-1-million-recovered

p ‘Financial Flows from Human Trafficking’, FATF, https://www.fatf-gafi.org/media/fatf/content/images/Human-Trafficking-2018.pdf

p ‘Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial RedFlags’, FinCEN, https://www.fincen.gov/sites/default/files/advisory/FIN-2014-A008.pdf

p ‘Anti-money laundering supervision: guidance for high value dealers’, HMRC,https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/686127/High_Value_Dealers_Guidance.pdf

p ‘18 arrests in international human trafficking operation’, Europol, https://www.europol.europa.eu/newsroom/news/18-arrests-in-international-human-trafficking-operation

p ‘Federal jury convicts Dallas woman in stolen identity refund scheme; some stolen identities belonged to incarceratedindividuals’, US Immigration and Customs Enforcement, https://www.ice.gov/news/releases/federal-jury-convicts-dallas-woman-stolen-identity-refund-scheme-some-stolen

p ‘Professional Money Laundering’, FATF, http://www.fatf-gafi.org/media/fatf/documents/Professional-Money-Laundering.pdf

23


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