Financial Institution Employee

These employees are knowingly or unknowingly involved by:

• Overriding transaction monitoring or security alerts without proper authorization.
• Altering system parameters to allow high-risk transactions to go unflagged.
• Manipulating internal records (e.g., vault holdings) and facilitating illicit asset transfers.

Complicit or subverted compliance employees within the MSB abet money laundering by:

• Failing to file required suspicious transaction reports.
• Overriding internal AML alerts or omitting negative indicators from customer documentation.

This hampers financial institutions’ ability to detect illicit flows, as key warning signs are removed at the source.

Corrupted or coerced employees, ranging from frontline staff to senior executives, facilitate infiltration by:

• Manipulating or disabling transaction monitoring and suspicious activity alerts.
• Rapidly onboarding high-risk customers and ignoring red flags or large unexplained deposits.
• Preventing or halting suspicious transaction reporting mandated by AML regulations.

Their complicity undermines institutional compliance, concealing criminal transactions and impeding oversight by regulators or outside auditors.

Certain employees or representatives of participating lenders collude with borrowers by:

• Overlooking red flags in trade documents, such as over-invoicing or missing shipment details.
• Facilitating loan approvals based on incomplete or falsified information.
• Bypassing internal controls, allowing criminals to secure and layer illicit funds through syndicated loan structures undetected.

Complicit employees enable record tampering by:

• Exploiting their privileged credentials or administrative access to alter, erase, or falsify transaction logs and account histories.
• Introducing false entries in corporate or bank records, impeding auditors and investigators attempting to verify transaction integrity.
• Concealing evidence of suspicious activity or inflating/deflating figures in official statements, hindering financial institutions’ monitoring and anomaly detection.