GRA · Financial Crime and Fraud Risk

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Money laundering risk

Money laundering disguises the criminal origin of funds so they can be used freely. Launderers exploit banks, payment firms, trade, real estate, professional services and virtual assets, and move value across borders. The FATF standards set the global response. This page sets out how laundering methods work at a general level, how risk is assessed and measured, and who decides on controls and enforcement.

01Register

Money laundering risk on the record.

02The question

Money laundering risk: how the risk develops.

AML typologies and governance. The dossier below sets out how the risk develops, what is measured, where the data come from, how it is modelled and who decides.

Mechanism

Placement, layering, integration

Funds enter the financial system, move through transactions designed to obscure their source, and return as apparently legitimate wealth. Each stage exploits different services.

Mechanism

Opaque ownership hides control

Shell companies, trusts and nominees conceal who owns and benefits from assets. Beneficial ownership registers aim to make control visible.

Mechanism

Trade moves value

Misinvoicing goods and services moves value across borders without moving money directly. Trade-based laundering is hard to detect from payment data alone.

Mechanism

Virtual assets add channels

Crypto-assets, mixers and unregulated exchanges offer speed and pseudonymity. The FATF travel rule extends information requirements to virtual asset transfers.

03Monitor

Alert triage and investigations.

The screen a team would use to follow this subject: its measures, states and decisions. Names are examples and values are illustrative.

Alert triage and investigations

Money laundering risk · Bank B monitoring · Today

  • Alerts today
    1070
  • Escalated to cases
    5pct of alerts
  • Open cases older than 30 days
    81Watch
  • Reports filed this month
    74Normal
Backlog above targetGRA · Financial Crime and Fraud Risk

Alert queue

  1. HRapid in-out through new accountsScenario TM-07 · score 852 h
  2. MTrade invoice price outlierScenario TB-03 · score 807 h
  3. MStructuring below thresholdScenario TM-02 · score 654 h
  4. LName match, sanctions listLikely false positive2 h

Counterparty network, case CS-3697

red: accounts under review

Case path

  1. Alertscenario
  2. Triageanalyst
  3. Investigatecase
  4. DecideMLRO
  5. Reportto FIU
  6. Feedbacktuning
Alert triage and investigations: the screen's structure, terms and states for Money laundering risk.Example names and illustrative values; a design, not a record or a live system.
04Indicators

What is measured, and how well.

Each indicator carries its unit, its cadence, the kind of source behind it and the evidence label a value would carry. No values are shown: a programme supplies them under its own authority.

IndicatorUnitCadenceSource typeLabel
National risk assessment publishedyes or no, with dateon publicationGovernment recordsPublished statistics
FATF effectiveness ratings by immediate outcomerating, categoricalper mutual evaluationFATF reportsPublished statistics
Jurisdictions on FATF increased monitoringcountthree times a yearFATF public statementsPublished statistics
Beneficial ownership register coverageshare of legal entitiesperiodicRegister statisticsREPORTED
Money laundering prosecutions and convictionscountannualJustice statisticsPublished statistics
Value of assets confiscatedcurrencyannualJustice statisticsPublished statistics
05Exposure, loss and capital

What money laundering risk means for exposure, loss and capital.

The exposure, loss, scenario and capital views a risk officer, supervisor or ministry of finance would ask for, with the frameworks they report against. Structures follow supervisory and actuarial practice. Values are illustrative: never prices, ratings or advice.

Transmission channels

How a shock in money laundering risk reaches credit, market, underwriting, liquidity and operational risk, and feeds back.

Channel structure after the Basel Committee's work on climate-related risk drivers and transmission channels; links shown are typical paths, not estimated exposures.
NGFS climate scenarios · Network for Greening the Financial SystemIFRS S2 Climate-related Disclosures · ISSBTCFD recommendations · Financial Stability Board TCFDPrinciples for the effective management of climate-related financial risks · Basel Committee on Banking Supervision
06Sources

Where the evidence comes from.

Named public datasets and institutional records, each with its licence class. Sources by agreement are used only under their terms and never republished.

SourceWhat it givesLicence class
FATF mutual evaluation reports and follow-up reportsAssessment of national AML/CFT systemsFree, FATF terms
FATF public statements on high-risk and monitored jurisdictionsLists of jurisdictions with strategic deficienciesFree, FATF terms
National risk assessmentsCountry assessments of money laundering threats and vulnerabilitiesPublic records, terms per government
Basel AML IndexComposite country risk index for money launderingFree to read, terms to check
UNODC research on illicit financial flowsEstimates and methods for illicit flowsFree, UN terms
07Decisions

Who decides, and what the evidence serves.

Financial Crime and Fraud Risk prepares evidence. The decisions below are taken by the authorities named, under their own rules, and never by the platform.

Who decidesThe questionEvidence this page serves
Governments and FATF membersHow to implement and assess the standardsMutual evaluation findings and national risk assessments
AML supervisorsWhich institutions and sectors to supervise most intensivelyRisk assessments and supervisory findings
Firm money laundering reporting officers and boardsWhat risk appetite and controls to setEnterprise risk assessment and typologies
Prosecutors and asset recovery agenciesWhich cases to pursue and assets to confiscateIntelligence and case evidence

Outputs this topic produces

  • Guide to the FATF standards and mutual evaluations
  • Brief on beneficial ownership transparency
  • Method note on reading national risk assessments
  • Questions for boards on enterprise-wide risk assessment
08Core questions

What experts ask.

Anti-money laundering researchers ask whether controls catch laundering or mainly generate process.

  • Which laundering methods are prevalent, and how do they adapt to controls?
  • How effective are anti-money laundering controls at detecting and disrupting laundering?
  • How is the risk-based approach applied in practice, and does it focus effort on real risk?
  • How do beneficial ownership transparency and professional enablers affect laundering?
  • What are the costs and unintended consequences of anti-money laundering controls?
09Mechanisms and drivers

Placement, layering, integration and enablers.

Laundering is often described in three stages: placing criminal proceeds into the financial system, layering them through transactions to obscure their origin, and integrating them into the legitimate economy. Methods include cash-intensive businesses, trade-based laundering, shell companies and trusts, real estate, mule accounts and digital assets. Professional enablers, such as lawyers, accountants and company service providers, can provide the structures that make laundering possible.

Anti-money laundering frameworks rely on a risk-based approach, beneficial ownership transparency, transaction monitoring and suspicious activity reporting. Research and evaluations suggest that controls detect only a fraction of laundering, that reporting volumes are high while useful intelligence is limited, and that compliance costs are significant. Improving effectiveness is a central theme.

10Methods and data

How the evidence is built, and where it stops.

  1. 01

    Typology research

    Studying laundering methods from cases and evaluations. Cases reflect detected laundering.

  2. 02

    Network analysis

    Mapping ownership and transaction networks with network science. Ownership data is incomplete.

  3. 03

    Effectiveness evaluation

    Assessing outcomes of controls, drawing on data engineering for data quality. Outcomes are hard to measure.

  4. 04

    Digital asset analysis

    Analysing flows on public ledgers with distributed ledgers and digital assets methods. Attribution of addresses is uncertain.

11Methods

How it is studied, and what the methods cannot say.

12Questions

Questions and answers.

What does the FATF do?
The Financial Action Task Force sets international standards against money laundering, terrorist financing and proliferation financing, and assesses countries through peer review.
What is beneficial ownership?
The natural person who ultimately owns or controls a legal entity or arrangement, or on whose behalf a transaction is conducted.
What is the travel rule?
A FATF requirement that originator and beneficiary information travels with transfers, extended to virtual asset service providers.
How much money laundering is detected?
Estimates are uncertain, but evaluations widely suggest that only a small share is detected and confiscated. Improving effectiveness is a central policy concern.
What is beneficial ownership transparency?
Requirements to identify the natural persons who ultimately own or control companies and trusts, so that anonymous structures cannot easily hide criminal funds.
Does GRA provide anti-money laundering compliance services?
No. GRA is not a law enforcement body, financial intelligence unit or regulator. It does not investigate cases, receive reports of suspicious activity, screen customers or hold customer data.
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Reports is the Consortium's quarterly publication. What you know about this subject can become evidence, a case or a correction in the next edition, credited to you and published under CC BY 4.0 where it is your own work.

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