Financial services that consolidate funds from multiple clients into a single account managed by a fiduciary or financial institution. Commonly used by law firms, investment firms, or real estate brokers to collectively manage client funds while keeping individual transactions and balances distinct within the pooled account.
Main/
Pooled Client Account Services
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Code
PS0056
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Name
Pooled Client Account Services
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Version
1.0
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Category
Deposit & Account Services
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Created
2025-03-14
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Modified
2025-04-02
Related Techniques
- Criminals route illicit proceeds through pooled accounts (e.g., attorneys’ IOLTA) maintained under professional privileges.
- This structure consolidates multiple clients’ funds, making it difficult to identify the true origin and ownership of each transaction.
- Consolidates funds from multiple participants into a single account, obscuring each contributor’s identity.
- When labeled as foreign investment, these pooled inflows blend illicit cash with legitimate assets and hinder AML tracing.
- Aggregate funds from multiple clients into a single account, obscuring direct links to sanctioned individuals.
- Reduces transparency of wealth ownership, hindering efforts to identify or freeze restricted parties’ assets.
- Consolidation of multiple investor deposits into a single pool conceals the flow of new capital paying out earlier participants.
- Large commingled balances hamper investigators’ ability to identify and segregate illicit contributions from legitimate investments.