Organized Crime Group

Organized crime groups orchestrate ATM structuring by:

• Coordinating or funding multiple individuals (or “smurfs”) to deposit small amounts of illicit cash into ATMs.
• Ensuring each deposit remains below reporting thresholds to evade monitoring or suspicion.

This fragmentation of funds across many deposits complicates financial institutions’ detection efforts, as suspicious activity may only become evident when deposits are aggregated across different accounts or locations.

Paramilitary or similarly structured groups exploit agricultural subsidies through:

• Fraudulent claims on farmland or livestock to secure illicit funds.
• Maintaining fear or corrupt relationships that deter scrutiny, ensuring continued fraudulent subsidies.

Organized crime groups purchase or operate farmland to:

• Obscure the true source of illicit funds by mixing them with seasonal agricultural revenues and government incentives.
• Manipulate land valuations (e.g., reclassification from farmland to building land) to inflate or reduce property values, hiding the actual flow of laundered capital.
• Present falsified financial statements or conceal sustained losses, complicating financial institutions' due diligence when assessing agribusiness operations.

Organized crime groups incorporate arms trafficking as a revenue source, using illicit proceeds to:

• Support other criminal enterprises or fund additional predicate offenses.
• Access financial channels, often through layering and structuring transactions that disguise the origins of arms-related funds.

Funds large-scale laundering operations and leverages automation to move drug- or fraud-derived cash through multicountry account webs in minutes.

Organized crime groups leverage bearer instruments by:

• Physically transferring them across borders or between associates, bypassing formal ownership records.
• Exploiting their anonymity to conceal illicit proceeds from financial institutions, hindering effective due diligence and monitoring.

Organized crime groups supply large volumes of illicit U.S. dollars derived from criminal activities. By selling these funds at a discount to informal peso brokers, they delegate the laundering process. This masks the criminal source of proceeds, as subsequent payments appear as standard trade transactions to financial institutions, making it harder to link the funds to predicate offenses.

Organized crime groups exploit bonded warehouses to:

• Conceal and store illicit goods (e.g., contraband alcohol, tobacco, or high-demand items) alongside legitimate shipments, frustrating audits and supply chain tracking.
• Re-route or funnel these goods near exit borders to black markets, further complicating regulatory oversight and customs controls.
• Manipulate shipping records, obscure beneficial ownership, and repeatedly alter cargo manifests, making it difficult for financial institutions to identify suspicious flows associated with inventory financing or trade-based transactions.

Organized crime groups knowingly manipulate carbon credit trading markets by:

• Orchestrating large-scale VAT carousel fraud, exploiting cross-border carbon credit trades.
• Rapidly moving illicit proceeds into offshore or shell accounts.

These activities obscure the funds’ origins, posing significant challenges for financial institutions attempting to trace suspicious transactions.

• Orchestrates the carousel fraud scheme by establishing or controlling multiple entities that repeatedly trade the same goods for VAT refunds.
• Launders proceeds derived from other predicate offenses by injecting them into these revolving transactions.
• Exploits international networks and inconsistent oversight, making it harder for financial institutions to identify ultimate beneficiaries.

Organized crime groups orchestrate the physical movement of illicit currency by:

• Recruiting individuals to carry large sums of concealed cash across borders.
• Coordinating routes, schedules, and concealment methods to avoid customs scrutiny.
• Colluding with corrupt officials and structuring transported amounts below reporting thresholds.

These tactics circumvent financial institution controls, hindering AML efforts to detect or trace the origin of funds.

Organized crime groups exploit the cash-based employment of undocumented workers by:

• Establishing or controlling front businesses that pay laborers off the books
• Blending illicit funds into wage disbursements, reducing traceability and complicating financial oversight

Organized crime groups orchestrate chip dumping schemes by:

• Recruiting or directing collusive players to conduct deliberate chip losses or wins across various casino tables or online platforms.
• Taking advantage of minimal KYC or weaker oversight in certain jurisdictions, enabling multiple accounts or fictitious identities to move funds covertly.
• Flooding financial institutions with seemingly legitimate gambling proceeds, complicating AML checks and source-of-funds verifications.

Organized crime groups orchestrate cigarette smuggling operations by:

• Financing, sourcing, and transporting contraband cigarettes across borders to exploit tax differentials.
• Employing bribery or intimidation to bypass customs checks and reduce detection risk.
• Laundering proceeds through multiple channels, complicating financial institutions' efforts to distinguish illicit funds from legitimate transactions.

Organized crime groups knowingly coordinate large-scale smuggling operations. They:

• Conceal illicit goods alongside legitimate cargo, creating complex supply chains that obscure the origin of funds.
• Use falsified shipping documents and multiple jurisdictions to layer illicit proceeds, making it difficult for financial institutions to trace transactions back to criminal sources.

Organized crime groups, including local street gangs, generate smaller but steady flows of illicit proceeds from theft, robbery, or assault-related extortion. They knowingly channel these funds into the financial system by:

• Splitting cash into multiple small deposits at cash-intensive businesses, peer-to-peer platforms, or informal remitters.
• Using low-value transactions to bypass typical monitoring thresholds, making detection more challenging for financial institutions.

Organized crime groups covertly acquire or partner with MSBs to:

• Embed complicit owners or staff who manipulate compliance processes.
• Blend illicit funds with legitimate transaction flows while evading suspicious transaction reporting.

These actions hamper financial institutions’ due diligence efforts by obscuring the illicit source of funds, potentially allowing large-scale laundering operations to continue undetected.

Organized crime groups knowingly orchestrate cross-border agent operations by:

• Deploying local fixers or sub-agents to open accounts and conduct fund transfers in different jurisdictions, concealing the true beneficial owners.
• Exploiting gaps or inconsistencies in AML enforcement across borders, fragmenting oversight and facilitating the layering of illicit proceeds.
• Presenting these transactions as legitimate local activity, making it more difficult for financial institutions to detect suspicious cross-border movements or identify the actual parties involved.

Organized crime groups exploit cross-border payment routing by:

• Coordinating complex international transfers through jurisdictions with weaker AML controls.
• Leveraging limited adoption of beneficial ownership data to obscure the true source and destination of illicit funds.

Organized crime groups drive large-scale drug trafficking operations by:

• Overseeing the production, distribution, and sale of controlled substances across multiple jurisdictions.
• Coordinating smuggling routes to source and move chemicals, equipment, and illicit drugs.
• Laundering drug proceeds through shell companies, trade-based schemes, or other financial channels.

Organized crime groups carry out large-scale environmental crimes, such as illegal logging or hazardous waste dumping, generating substantial illicit proceeds. They:

• Exploit corruption and bribery to secure or falsify permits, avoiding enforcement.
• Use front companies and layered transactions across multiple jurisdictions to obscure beneficial ownership.
• Employ trade-based laundering schemes with falsified invoices, mingling illegal funds with legitimate commerce.

Organized crime groups drive extortion by threatening businesses or individuals and collecting recurring payments.

• They coerce victims into handing over cash or bank transfers under the guise of 'protection fees.'
• After collecting these funds, they deposit or commingle them with legitimate revenues, concealing the extorted source from financial institutions.

Organized crime groups exploit high-value goods to launder illicit proceeds by:

• Purchasing gold, diamonds, artwork, or collectibles with criminal funds while relying on minimal regulatory oversight.
• Engaging in repeated buy-sell cycles, including cross-border transactions, to layer funds and hide their illicit origin from financial institutions.

Organized crime groups orchestrate large-scale illegal logging by:

• Bribing or coercing local officials to obtain falsified permits.
• Coordinating cross-border shipments of illicit timber.
• Laundering criminal proceeds through banks, shell companies, and trade finance services to obscure the source of funds.

Organized crime groups knowingly direct unauthorized mineral extraction and sales, profiting from the illicit proceeds. They:

• Oversee unlicensed mining operations and bypass legitimate permitting.
• Merge illicitly mined ore with lawful supply to disguise its illegal origin.
• Funnel proceeds into financial accounts, falsely characterizing them as legitimate revenue from mineral sales, complicating due diligence for financial institutions.

• Illegally acquire or loot cultural artifacts, then sell them through illicit channels.
• Coordinate multiple cross-border transactions and repeated resales at manipulated prices to layer criminal proceeds.
• Collaborate with shell companies and intermediaries to obscure the ultimate source and ownership of funds.
• Challenge financial institutions by masking seemingly legitimate art deals behind complex ownership chains.

Organized crime groups exploit gambling channels to launder illicit funds by:

• Depositing large amounts of illicit cash or transferring criminal proceeds into gambling accounts.
• Minimally wagering or placing bets on both sides of an event to guarantee low net losses.
• Coordinating chip-dumping and match-fixing schemes, often relying on forged receipts or staff collusion.

These tactics obscure beneficial ownership and complicate financial institutions' ability to identify the true source of funds when processing gambling-related transactions.

Organized crime groups orchestrate the infiltration of banks or non-bank financial institutions by:

• Acquiring partial or full ownership stakes to gain control over governance and compliance.
• Placing loyal personnel or subverting existing leadership, thereby disabling or falsifying AML controls.
• Exploiting correspondent banking channels and large-volume transactions under minimal scrutiny.

Their control over the institution severely compromises compliance frameworks, ensuring illicit funds pass undetected and unreported.

Organized crime groups exploit instant exchange services by:

• Rapidly converting illicit proceeds across multiple currencies or digital assets to mask their origin.
• Leveraging minimal or nonexistent KYC requirements, making it harder for financial institutions to trace layered transactions or identify ultimate beneficiaries.

These groups channel proceeds from fraud, Ponzi schemes, or other predicate offenses into private investment companies, hedge funds, or private equity structures. By commingling illicit and legitimate assets, they:

• Conceal the true source of funds behind formal investment operations.
• Exploit cross-border transactions and repeated layering, hindering financial institutions' ability to trace underlying criminal proceeds.
• Ultimately withdraw or redeem funds as ostensible profits or capital gains, further obscuring their origin.

Organized crime groups orchestrate the infiltration or acquisition of licensed betting shops to launder illicit proceeds.

• They place repeated, structured wagers below reporting thresholds, splitting larger funds into multiple smaller bets.
• They bribe or coerce employees to manipulate records or bypass AML checks.
• Financial institutions face difficulty distinguishing these laundered earnings from legitimate gambling proceeds when deposits or transfers occur.

These criminal groups perpetrate lottery scams by:

• Impersonating legitimate sweepstakes to collect advance fees from victims.
• Establishing operations across multiple jurisdictions (e.g., West Africa, Spain, Canada) to evade detection.
• Laundering the proceeds through structuring and layering, often via remittance services.

Their cross-border approach and use of multiple payment channels complicate financial institutions’ efforts to accurately identify and trace illicit funds.

Organized crime groups, including drug trafficking organizations, systematically exploit lottery systems by:

• Purchasing or acquiring winning tickets from legitimate winners, transforming illicit cash into apparent lottery earnings.
• Splitting large prizes with the original ticket holder, paying a premium to secure the winning claim.

These practices obscure the true source of funds, complicating financial institutions' transaction monitoring and beneficial ownership checks.

They orchestrate match-fixing schemes by funding bets with illicit capital and bribing or coercing sports professionals to ensure a winning result. The rigged payouts then enter financial channels disguised as legitimate gambling earnings, complicating AML controls.

Organized crime groups exploit micro-structuring by:

• Coordinating multiple individuals (or 'smurfs') to make repeated small deposits below reporting thresholds.
• Distributing transactions across multiple accounts and channels to avoid detection by automated systems.

These tactics overwhelm financial institutions’ monitoring and make it difficult to link fragmented deposits to larger illicit sums.

Organized crime groups may operate or partner with smuggling networks, leveraging established infrastructure to profit from human smuggling. They:

• Manage segments of the smuggling route, providing protection and logistical resources.
• Employ layered financial transactions to launder smuggling revenue alongside other illicit funds, impeding detection by financial institutions.

Organized crime groups exploit Node Exchange Provisioning by:

• Coordinating trusted intermediaries to swiftly convert illicit funds between fiat currency and cryptocurrency.
• Leveraging informal exchange networks with minimal or no KYC, shielding their operations from detection.
• Conducting rapid cross-border fund movements that hinder financial institutions’ ability to track transaction flows or attribute them to underlying criminal activities.

Organized crime groups exploit OTC and peer-to-peer cryptocurrency trading to:

• Convert bulk illicit proceeds into digital currencies without attracting attention from regulated exchanges.
• Conduct repeated layering steps through multiple OTC brokers, hindering investigators’ ability to trace funds.
• Leverage cash deliveries to facilitate rapid transactions and maintain anonymity, challenging financial institutions’ detection efforts.

Organized crime groups orchestrate pig butchering scams by:

• Recruiting or coercing individuals, sometimes through labor trafficking, to operate scam call centers.
• Establishing false relationships with victims online to build trust before urging them to invest.
• Controlling fraudulent or manipulated trading platforms and crypto wallets, then swiftly rerouting victim deposits through multiple accounts to obscure their origin.

Organized crime groups engage in maritime hijackings or hostage situations to demand ransoms. They manage the laundering of these ransom proceeds by:

• Exploiting the transnational nature of shipping routes to conceal the origins of the ransoms.
• Using complex cross-border transactions that hinder financial institutions' ability to detect illicit flows.

Organized crime groups orchestrate precious commodity smuggling by:

• Purchasing gold or gemstones with illicit proceeds.
• Using personal couriers, concealed compartments, or falsified documents to move valuables across borders.
• Reselling or bartering these goods in regions with lax controls to reintroduce funds into financial channels.

Their coordinated networks reduce detection risk and leverage multiple jurisdictions to launder illicit profits.

• Demands recurring protection fees from businesses or individuals under threat.
• Intermingles these extorted funds with legitimate revenues, making it difficult for financial institutions to detect the illicit origin.

These groups systematically profit from forced prostitution, trafficking, and other forms of sexual exploitation. They frequently operate across jurisdictions, utilizing sophisticated laundering channels such as funnel accounts, structured transactions, and virtual currencies to conceal illicit proceeds. By orchestrating trafficking networks, they create complex financial flows that challenge financial institutions' ability to detect and disrupt related money laundering.

Organized crime groups use shell companies to:

• Conceal illicit proceeds behind a semblance of legitimate corporate activity.
• Register entities in secrecy-friendly jurisdictions to move funds without attracting law enforcement scrutiny.

Organized crime groups orchestrate high-value sports betting, sponsorship deals, and match-fixing by:

• Injecting illicit proceeds into bets, club funding, or image-rights arrangements.
• Employing cross-border transfers and complex financial layering to prevent institutions from easily tracing the criminal origins of funds.

Perpetrators orchestrate timeshare scams by:

• Contacting owners under the guise of offering resale or exit deals that require upfront payments.
• Impersonating brokers, attorneys, or real estate professionals using stolen or fabricated credentials.
• Pressuring victims to pay repeated 'taxes', 'closing costs', or 'marketing fees' before disappearing with the illicit proceeds.

They ultimately launder collected fees through various accounts and offshore channels, making it harder for financial institutions to trace the origin of funds.

Organized crime groups orchestrate trade diversion to launder significant amounts of illicit proceeds. They:

• Coordinate multi-jurisdictional shipping routes and documentation to obscure the origin of funds.
• Exploit seemingly legitimate trade flows, making it difficult for financial institutions to detect irregular patterns among numerous cross-border transactions.

• Move illicit proceeds through rapid, successive transactions across multiple jurisdictions.
• Split funds into smaller amounts to avoid triggering reporting thresholds.
• Create layered transaction chains that hinder financial institutions' ability to trace ultimate beneficiaries.

Organized crime groups protect or manage underground gambling venues by:

• Overseeing unlicensed operations that allow criminals to introduce large volumes of illicit cash as wagers.
• Controlling the environment to limit identification requirements, helping obscure the ownership and movement of funds.

This arrangement hinders financial institutions' ability to trace the flow of illicit proceeds, as they appear to be legitimate gambling revenues.