Professional Money Launderer

An individual, group, or network that provides specialized services to transfer or conceal funds on behalf of third parties, often employing complex financial or corporate structures across multiple jurisdictions to obscure the origin or ownership of assets.

[
Code
AT0047
]
[
Name
Professional Money Launderer
]
[
Version
1.0
]
[
Category
Criminal & Illicit Networks
]
[
Created
2025-03-12
]
[
Modified
2025-04-02
]

Related Techniques

They knowingly exploit lightly regulated or alternative payment channels, including cryptocurrencies and prepaid cards, to layer illicit funds. By orchestrating rapid transfers outside mainstream banking oversight, they hinder financial institutions' ability to identify the true beneficiaries or sources of funds.

Professional money launderers orchestrate valuation manipulation by:

  • Coordinating with complicit intermediaries, appraisers, or sellers to disguise the true origin and amount of illicit funds.
  • Exploiting inaccurate valuations to justify large inflows or outflows of money, hindering financial institutions' transaction monitoring.

Designs and operates the scripting infrastructure, rents out mule accounts, and choreographs the rapid-fire layering flows for multiple criminal clients.

Professional money launderers employ burn-and-mint transfers to:

  • Destroy tokens on one chain by sending them to non-recoverable burn addresses, eliminating direct links to illicit funds.
  • Re-mint equivalent tokens on a different blockchain, breaking the audit trail and complicating chain analytics.
  • Leverage minimal-KYC cross-chain bridging solutions or decentralized exchanges to further conceal the origin of re-minted tokens, impeding investigators’ ability to track the source of funds.

Professional money launderers organize the circular letter-of-credit scheme by:

  • Setting up or managing shell companies across multiple jurisdictions.
  • Coordinating interlocking letters of credit so that each bank sees only a small, seemingly legitimate portion of the transaction.

This layering approach conceals the illicit origin of funds and complicates banks’ due diligence, as each letter of credit appears valid when viewed in isolation.

Professional money launderers knowingly orchestrate circular transactions by:

  • Setting up multiple accounts or entities across different jurisdictions, repeatedly transferring illicit proceeds to frustrate tracking efforts.
  • Employing phantom trade deals or complex re-invoicing to conceal the true origin and ownership of funds, impeding financial institutions' ability to detect suspicious flows.

Professional money launderers create or gain control of MSBs to:

  • Oversee funds entering and leaving the MSB under the guise of legitimate transactions.
  • Manipulate internal records or staff to bypass or minimize suspicious reporting.

This approach undermines financial institution efforts to implement AML controls, as external counterparties may receive incomplete or misleading compliance data.

Professional money launderers orchestrate the use of complex corporate structures by:

  • Registering or managing multiple business entities across different jurisdictions to layer illicit funds.
  • Leveraging specialized knowledge of regulatory gaps and corporate governance to conceal ultimate beneficiaries and launder proceeds.

Professional money launderers orchestrate countertrade schemes by:

  • Creating or coordinating multiple invoices with inflated or falsified valuations for goods or services.
  • Distributing reciprocal transactions across various jurisdictions, obscuring the true source of funds and beneficial ownership.
  • Employing informal or hawala-based channels to settle payment imbalances, bypassing normal banking rails.

This dispersal of activity frustrates financial institutions' due diligence, as the layered trade invoices appear legitimate yet conceal illicit proceeds.

Professional money launderers specialize in structuring and layering funds across diverse financial channels by:

  • Selecting intermediary banks or corridors with inconsistent oversight.
  • Capitalizing on delayed adoption of standardized identifiers (e.g., LEIs) to fragment audit trails and evade detection.

Professional money launderers coordinate successive currency exchanges by:

  • Seeking out licensed or unlicensed exchange services that have weak AML controls or complicit operators.
  • Structuring funds into smaller amounts, converting them repeatedly to different currencies, and transferring the proceeds across multiple accounts.

This repeated layering hinders financial institutions' ability to detect suspicious transaction patterns and trace the original source of illicit funds.

Professional money launderers use decentralized mixers to:

  • Deposit and blend illicit proceeds within non-custodial smart contracts, breaking traceable links between input and output addresses.
  • Evade centralized oversight or intervention by eliminating a single operator or custodian.

These actions frustrate financial institutions' AML efforts by reducing visibility into transaction flows and hindering timely freezes or seizures of tainted funds.

  • Engages in forging or procuring falsified documents (e.g., counterfeit IDs, bank records) to support layering or integration tactics.
  • Presents these forged materials to financial institutions to evade standard monitoring and obscure beneficial ownership, frustrating attempts to trace illicit proceeds.
T0142
|
|

Professional money launderers support drug trade networks by:

  • Structuring funds across multiple financial accounts or funnel accounts.
  • Implementing layering tactics that obscure the true source of drug-derived revenues.
  • Integrating illicit earnings into legitimate business channels to avoid detection.

Professional money launderers facilitate this subtechnique by:

  • Establishing or managing bogus consulting firms that move illicit funds under the guise of advisory fees.
  • Providing phony documentation and layering transactions across multiple jurisdictions, obstructing financial institutions' due diligence.

Professional money launderers facilitate fictitious foreign investment schemes to reintroduce illicit proceeds as inbound capital.

  • They route illicit funds through cross-border transactions labeled as foreign direct investment, obscuring the criminal origin.
  • They manipulate corporate or investment documents to legitimize inflows, making it difficult for financial institutions to detect underlying illicit activity.

Professional money launderers facilitate fictitious sales by:

  • Creating or advising on sham invoicing schemes and staged auctions on behalf of criminal clients.
  • Structuring transaction flows through multiple accounts and jurisdictions, ensuring illicit income appears as legitimate commercial proceeds.

By crafting sophisticated paper trails, they help clients evade scrutiny from financial institutions’ compliance checks and law enforcement inquiries.

Professional money launderers coordinate and execute foreign exchange manipulations by:

  • Over or under-invoicing cross-border transactions to disguise the real value of goods or services.
  • Structuring partial or advanced payments through multiple jurisdictions.
  • Employing derivatives or hedging instruments to legitimize irregular currency movements in FX markets.

Offers specialised laundering services—designing cash-injection patterns, managing trade-finance paperwork, and coordinating cross-border transfers—so the front business can process higher volumes of illicit funds without triggering red flags.

Professional money launderers employ instant exchange services to:

  • Execute frequent cross-asset conversions that thwart conventional AML monitoring.
  • Conceal beneficial ownership by exploiting platforms with weak customer due diligence, complicating financial institutions' investigations.

Professional money launderers orchestrate or direct private equity and hedge fund schemes by:

  • Coordinating with or establishing investment vehicles that classify illicit funds as legitimate capital calls, subscriptions, or redemptions.
  • Manipulating records and performance data to conceal suspicious fund flows.

This impedes financial institutions' detection and investigation processes by embedding illicit proceeds within seemingly standard investment transactions.

Professional money launderers design and execute multi-currency swaps by repeatedly converting illicit funds among various fiat currencies and jurisdictions. They exploit loopholes in AML controls and arbitrage opportunities to create multiple layers of transactions, obscuring the original source of the proceeds. This fragmentation complicates financial institutions' monitoring efforts and allows launderers to circumvent standard scrutiny thresholds.

T0015.004
|
|

Professional money launderers leverage multi-hop VPNs to:

  • Conceal IP addresses and hinder IP-based location checks by financial institutions.
  • Bypass region-based AML controls by presenting different or conflicting geolocations.
  • Fragment digital footprints across multiple routing layers, making it more difficult for investigators to trace suspicious transactions and identify beneficiaries.
T0023.002
|
|

Sources stolen-ID components, commissions document forgers, and packages “alias kits” (ID, utility bill, device fingerprint) for clients. Their value proposition is selecting spellings that test just below fuzzy-match thresholds, registering those aliases at several banks, and handing over ready-made accounts whose names are deliberately one character away from sanctions or SAR history.

Professional money launderers arrange private, undocumented transfers or asset exchanges on behalf of criminal clients, ensuring no official record exists and no KYC checks are triggered. By coordinating these stealth deals, they obscure the flow of illicit funds, posing significant challenges for financial institutions to trace or identify suspicious transactions.

T0015.005
|
|

Professional money launderers use Onion over VPN connections to:

  • Obscure their real-world identities when accessing virtual asset exchanges or peer-to-peer trading platforms.
  • Thwart IP-based monitoring and geolocation checks, making it harder for financial institutions to detect or link suspicious transactions.

This multi-layered anonymity channel facilitates the seamless layering of illicit funds, diminishing the effectiveness of AML teams' traceability efforts.

Professional money launderers exploit online gambling sites by:

  • Creating multiple player accounts with minimal or falsified KYC details.
  • Depositing illicit funds in small, structured increments to avoid detection.
  • Placing only minimal or hedged bets to simulate routine gambling activity, then withdrawing or transferring balances as purported winnings.

Such practices challenge financial institutions’ transaction monitoring because funds re-enter the formal banking system labeled as legitimate gaming returns.

T0070.002
|
|

Professional money launderers implement peel chains by:

  • Generating numerous addresses to receive incremental transfers from a large illicit balance.
  • Automating the peeling of funds, splitting them into micro-transactions that typically avoid detection.

They orchestrate the workflow, ensuring that each individual transaction appears minor, complicating financial institutions’ oversight when attempting to link funds back to their criminal origin.

T0034.001
|
|

Professional money launderers exploit privacy wallets to:

  • Layer and commingle client funds through coinjoin protocols or stealth addresses, deliberately breaking transaction chains and obscuring beneficial ownership.
  • Repeatedly move illicit assets between transparent and privacy-focused blockchains to degrade institutional oversight and hamper attempts to link funds to a single origin.

This orchestrated use of privacy features greatly complicates financial institutions’ due diligence efforts, as it conceals transactional trails and makes it difficult to identify patterns or detect connections to predicate crimes.

Professional money launderers leverage remote identity deception by:

  • Exploiting lax online verification processes with synthetic or manipulated profiles, circumventing in-person due diligence.
  • Creating and operating multiple digital accounts under false identities to layer or integrate illicit proceeds.

This approach circumvents robust scrutiny, enabling more seamless laundering flows through remotely onboarded accounts.

Professional money launderers incorporate self-hosted wallets to:

  • Layer funds through rapid transfers between wallets under their control, separating transactions from the original source.
  • Integrate privacy-enhancing features (e.g., coinjoin) to obscure beneficiary details and hamper investigative efforts.
  • Exploit the absence of centralized oversight to avoid freezes or blocks on illicit proceeds, creating significant challenges for financial institutions attempting to trace or interdict suspicious activity.

Professional money launderers establish or acquire shell companies to:

  • Create complex cross-border transaction chains that obscure illicit fund origins.
  • Provide a corporate façade shielding their clients’ true involvement.

Financial institutions struggle to identify the ultimate beneficiaries behind these structures, undermining due diligence efforts.

Professional money launderers design and execute complex trade diversion frameworks by:

  • Structuring multi-layered transactions and leveraging fraudulent shipping or financial documents.
  • Concealing beneficial ownership, which hampers financial institutions' due diligence and monitoring of cross-border trade transactions.
  • Specialize in designing multi-layered transaction chains across both traditional and crypto channels.
  • Use rapid conversions, chain hopping, and micro-transfers to evade reporting triggers.
  • Financial institutions struggle to detect these recurring patterns due to the speed and complexity of layering operations.

Professional money launderers exploit virtual IBANs by creating multiple references that all link back to a single underlying account. This multiplies the layers in fund flows and hampers beneficial ownership checks, frustrating financial institutions' efforts to detect and monitor suspicious activity.

Professional money launderers employ virtual tokens for layering by:

  • Rapidly converting illicit proceeds among various tokens (including stablecoins, governance tokens, or DeFi tokens) to obscure the original source of funds.
  • Utilizing cross-chain bridging protocols, scattering transaction records across multiple blockchains.
  • Exploiting minimal- or no-KYC platforms, preventing clear identification of the ultimate beneficial owner.
T0094.002
|
|

Professional money launderers organize wash trading schemes by:

  • Setting up multiple accounts, wallet addresses, or shell structures to cycle illicit funds through repeated trades.
  • Coordinating rapid, offsetting transactions that mask the true origin of money and generate fictitious trading profits.

Financial institutions struggle because these intermediaries actively design complex layering strategies that resist standard detection measures.

They orchestrate wire transfer chains by:

  • Arranging multiple rapid transfers across different banks or jurisdictions to disguise the origin of funds.
  • Splitting large sums into smaller, routine-sized wire transfers to avoid detection thresholds.
  • Coordinating personal, third-party, or shell accounts to obscure true beneficiaries and mask illicit proceeds from financial institutions.