Professional Money Laundering Networks

Organizations that specialize in moving or concealing illicit proceeds on behalf of criminal actors or enterprises, often operating in multiple regions or industries.

[
Code
AT0055
]
[
Name
Professional Money Laundering Networks
]
[
Version
1.0
]
[
Category
Criminal & Illicit Networks
]
[
Created
2025-03-12
]
[
Modified
2025-04-02
]

Related Techniques

Provides end-to-end “as a service” automation, including scripting, mule recruitment, account provisioning, and cross-asset conversion to defeat detection.

These networks knowingly orchestrate laundering operations by compartmentalizing tasks among multiple individuals:

  • Each member handles a distinct function, such as only accepting cash deposits or routing wire transfers, without seeing the entire flow of illicit funds.
  • By fragmenting information, they reduce the risk that any single participant can expose the broader operation to financial institutions or authorities.
  • This approach exploits institutional data silos, preventing the detection of aggregated transactions across multiple channels.

Some illicit networks organize and streamline money mule recruitment, leveraging a broader infrastructure to:

  • Quickly establish cross-border flows of illicit funds through mule-managed accounts.
  • Provide recruitment guidance and financial instructions that obscure the true origin of criminal proceeds.
  • Exploit account holders in different jurisdictions, making it difficult for financial institutions to identify and block suspicious transactions across various regions.

These networks orchestrate multi-jurisdictional corporate structures by:

  • Forming and interlinking shell entities across secrecy-friendly jurisdictions to obscure beneficial ownership.
  • Coordinating with legal, accounting, and corporate service professionals to ensure minimal transparency.

They deploy nominee shareholders or directors to mask criminal control and hinder financial institutions’ KYC checks.

T0023.002
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Operates an industrial pipeline of alias identities: tracking which spellings have cleared which institutions, rotating clients through fresh variants as soon as a name is contaminated by a suspicious-activity report, and maintaining cross-border drop accounts registered to each spelling. This network effect makes simple name tweaks scale far beyond a single customer.

These networks specialize in orchestrating offshore layering schemes by:

  • Coordinating multiple offshore entities, nominees, and banking channels.
  • Executing complex cross-border transfers that disguise illicit funds as legitimate transactions.

Financial institutions struggle to identify, trace, or block these structured transactions, increasing the risk of inadvertently facilitating offshore laundering.

T0015.002
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Professional money laundering networks leverage proxy servers to:

  • Conceal the true IP addresses of their members, making it more difficult for financial institutions to detect or address suspicious session activity based on location.
  • Rapidly switch proxy endpoints, hindering attempts to link multiple transactions or logins to a single origin.
  • Exploit anonymizing networks (like Tor) to mask the group’s infrastructure, undermining IP-based traceability and complicating law enforcement investigations.

These networks orchestrate complex cross-border trade manipulations by:

  • Coordinating over- or under-invoicing and phantom shipments, obscuring the source or destination of funds.
  • Cycling re-invoicing processes across jurisdictions, making it difficult for financial institutions to match payments to actual goods or services.
  • Exploiting uneven AML enforcement in multiple countries, layering illicit proceeds within legitimate trade flows.