Third-Party Payment Services

Outsourced processors supply high-volume API endpoints; criminals batch-upload mass payouts or pulls, dispersing value through many downstream banks before recall windows close.

• Criminals use intermediary payment providers with inconsistent AML checks to settle cross-game or off-platform transactions.
• Limited identity verification allows seamless fund transfers between multiple accounts and services.

• These services act as a middle layer between the payer and beneficiary, potentially masking the real beneficiary or origin of funds.
• Criminals instruct third parties to settle invoices or receive funds, complicating beneficial owner checks and audit trails.

• These intermediary platforms facilitate settlements and invoicing on behalf of merchants or individuals, potentially leaving the principal institution unaware of sub-agents managing funds.
• The agent-based model disperses transactional records across multiple third parties, reducing transparency for AML investigators.
• Criminals exploit minimal oversight in partner outlets to handle high-risk transfers under a legitimate service provider’s umbrella.

• White-label or aggregator frameworks allow sub-agents to operate under the provider’s license, concealing sub-agent identities and activities.
• Transaction details typically reflect only the aggregator’s name, reducing transparency into underlying sub-agent transactions and beneficial ownership.
• Fragmented responsibility over AML/CFT controls leads to inadequate oversight, creating opportunities for illicit funds to flow undetected.

• Payments are made or received by unrelated third parties, distancing illicit proceeds from their true origin.
• Layering of funds through multiple payers or payees creates complex transaction chains that challenge AML controls.

• Criminals open or misuse accounts at third-party payment providers (TPPPs), sometimes without the genuine merchant’s awareness, to process unauthorized transactions.
• Aggregating multiple merchants’ funds into unified settlement accounts obscures beneficial ownership and complicates detection of illicit activity.