Money Transfer and Remittance Services

• Money mules can funnel illicit proceeds across borders under the guise of remittances.
• Structured or frequent transfers cloak the true origin and intended recipient, obscuring money trails.

• Criminals leverage lightly regulated or unregistered remittance providers to transfer funds internationally following casino-based layering.
• Splitting transfers across multiple patrons or entities helps mask the funds’ origin and dodge reporting thresholds, making it harder for authorities to track illicit proceeds.
• Jurisdictional loopholes and limited oversight at some remittance outlets further obscure the money trail.

• Unlicensed or loosely regulated remittance operators can mirror hawala-like operations, using personal trust instead of formal KYC to accept and move significant sums.
• Commingling legitimate remittances with illicit funds and minimal recordkeeping obscures transactional traces, allowing criminals to bypass formal banking oversight.

• Unlicensed operators offer informal channels to move funds across borders or domestically without proper registration or oversight.
• They accept cash or value from customers and dispense equivalent payouts in other jurisdictions, bypassing standard AML checks.

• Criminals exploit informal hawala networks that operate outside formal licensing and KYC requirements.
• Deposits of illicit proceeds can be made to a hawaladar’s pooled account, leaving no official record or paper trail.
• Cross-border or domestic payouts are arranged through trust-based relationships, effectively bypassing regulatory monitoring and AML detection.

• Peso brokers may use money transfer platforms to move criminal proceeds internationally under the guise of legitimate remittances.
• Third-party or intermediary payments with insufficient documentation allow illicit funds to be channeled to exporters, completing the cycle of the Black Market Peso Exchange.

• Offenders split large sums into numerous low-value transfers that remain below reporting thresholds.
• They use multiple senders, recipients, or remittance outlets to distribute the funds, thwarting suspicious transaction monitoring.

• Criminals can repeatedly send small sums through remittance channels to multiple receivers, ensuring each transaction remains below regulatory thresholds.
• Frequent low-value international transfers appear typical for personal remittances, hindering detection of aggregated illicit funds.

• Criminal or complicit remittance providers intercept legitimate remittance details and deposit illicit proceeds in their place, masking the criminal origin.
• Recipients see what appears to be a routine inbound payment, allowing illicit funds to blend seamlessly with genuine remittances.

• Criminals split illicit funds into multiple low-value transfers under various sender identities, avoiding formal reporting thresholds.
• Limited checks for smaller transactions allow them to deposit and withdraw proceeds with minimal scrutiny.
• Transfers often converge on a single beneficiary lacking a legitimate connection to the senders, obscuring the money trail.
• Funds are regularly collected in cash soon after arrival, further frustrating AML monitoring and tracing efforts.

• Criminals execute numerous small transfers via remittance channels, each below monitoring thresholds.
• They often involve multiple senders or recipients to disguise the cumulative value and origin of illicit proceeds.

• Multiple accounts can be opened quickly with fabricated personal data, enabling rapid movement of illicit proceeds across borders.
• Discrepancies between the provided identity details and third-party validations often signal identity tampering or fraud.

• Criminals use stolen or fabricated personal details to open multiple remittance accounts simultaneously, camouflaging large volumes of transactions.
• By presenting consistent yet false KYC information, they maintain minimal scrutiny while rapidly transferring illicit proceeds internationally.

• Offenders send small remittances across various corridors to observe whether they prompt additional due diligence.
• Low-value cross-border transfers help identify each corridor’s threshold or KYC intensity.

• Criminals falsely label remittance transfers as personal gifts, familial support, or charitable donations, providing documents (e.g., gift letters) to reduce scrutiny.
• They often send amounts exceeding the sender’s known financial profile or route funds through regions lacking any genuine familial or organizational link, concealing the true source.
• By misrepresenting the transaction purpose, offenders evade common AML checks and appear compliant with routine remittance norms.

• Criminals compel overseas individuals or businesses to send forced payments, routing them through remittance channels.
• Large or frequent cross-border transfers labeled with ambiguous references can conceal extortion proceeds and finance illicit operations.

• Multiple small cash deposits are submitted at different remittance outlets, both locally and across borders, disguising the true origin of funds.
• The fragmented nature of these transactions makes it harder for authorities to identify a single underlying criminal operation.

• After inflating diamond shipment invoices, criminals integrate illicit proceeds by transferring funds across multiple remittance channels, especially where controls may be weaker.
• Layering is further facilitated by rapid fund transfers to and from different jurisdictions, making detection of the true transaction origin more difficult.

• Smaller, frequent transfers are sent via remittance providers to co-conspirators or family abroad, disguising the scope of illicit cash flows.
• In less monitored corridors, criminals exploit minimal documentation requirements to launder sexual exploitation revenue.

• Criminals deposit smuggling proceeds into remittance channels under individual transaction limits to evade detection.
• Transactions often match known smuggling fee amounts, masking their illicit origin and facilitating cross-border fund movement.

• Enables frequent, low-value cross-border transfers, making it harder to piece together the original illicit funds flow.
• Criminals exploit multiple remittance corridors and micro-transactions to bypass alerting triggers and conceal beneficiary identities.

• Allows repeated, small-value transactions across diverse remittance channels, contributing to layering by dispersing illicit funds into multiple accounts or payments.
• Rapid processing and global coverage enable criminals to move funds quickly, making consolidated oversight more difficult and frustrate detection efforts.

• Criminals can direct unrelated or complicit third parties to initiate or receive remittances on their behalf, obscuring true fund ownership.
• Structured or repeated transfers from multiple outside payers complicate beneficial ownership checks and hamper effective monitoring.

• Criminals pose as legitimate individuals using forged identification to open or access remittance accounts.
• They send or receive funds internationally under the stolen identity, hampering the integrity of KYC checks and obscuring the true beneficiary.

• Criminals utilize reciprocal remittances or hawala-style transfers to settle imbalances in countertrade deals.
• These off-grid or loosely monitored channels fragment payment trails, hindering authorities’ ability to track the ultimate origin or destination of funds.

• Criminals can insert complicit staff or owners to omit suspicious transaction reporting, blending illicit proceeds with regular remittance flows.
• Large agent networks enable transactions to be divided among multiple outlets, obscuring patterns and hampering regulatory oversight.

• Criminals deposit multiple structured sums of illicit proceeds across different remittance agents or online portals.
• The funds are then rapidly transferred or withdrawn in other regions, obscuring the initial sources of the deposits and frustrating investigators.

• Criminals leverage sub-agents or partner outlets operating under a licensed principal to process funds, reducing direct AML scrutiny.
• The receiving institution often sees only the main provider (aggregator), obscuring the true source and final beneficiary.
• Sub-agents may accept multiple small deposits below reporting thresholds, fragmenting transaction records and complicating oversight.

• Criminals introduce loosely supervised sub-agents or partner outlets that directly handle funds, bypassing full KYC/AML checks under the principal license.
• The principal or aggregator name alone appears on many transaction records, obscuring the sub-agent’s involvement and the ultimate sender or beneficiary.
• Complex agent networks fracture oversight, enabling criminals to mask higher-risk transactions as standard remittances.

• Function as money service businesses, allowing frequent cross-border transfers in different currencies.
• Facilitate structured layering by breaking transactions into smaller amounts, often below reporting thresholds and during high-traffic periods, complicating the tracing of illicit origins.

• Criminals repeatedly convert illicit funds into different currencies by routing them through cross-border remittance channels.
• They split or structure transactions below reporting thresholds, exploiting weak controls in certain corridors to hide the true origin of funds.

• Criminals split illicit proceeds into multiple smaller remittances across different corridors, circumventing reporting thresholds and scrutiny.
• They exploit poorly regulated or informal remittance channels to layer funds internationally, obscuring the ultimate source or beneficiary.

• Local or regional sub-agents can channel illicit funds under the guise of personal or family remittances, fragmenting oversight across multiple jurisdictions.
• Small, frequent transfers help evade detection thresholds and complicate AML controls, enabling layered cross-border movements.

• Criminals break up large declared sums into smaller remittance transactions, staying below reporting thresholds and evading heightened scrutiny.
• They present customs declaration documents as evidence of lawful origin, even if the actual amount physically imported was lower.
• By spreading transactions across multiple recipients or locations, perpetrators further complicate investigations into the funds’ illicit source.

• Some remittance platforms, especially app-based, impose minimal KYC checks, allowing criminals to transfer funds covertly across borders.
• Rapid settlement and limited oversight hinder effective AML transaction monitoring, aiding layering and placement.

• In jurisdictions with weak regulation, informal or hawala-style services bypass formal monitoring.
• Criminals deposit fragmented illicit funds and move them offshore via lightly regulated corridors, complicating AML enforcement.

• Criminals utilize non-bank remittance or money transfer operators with lax oversight to move dirty funds through mobile channels.
• Frequent cross-border micro-remittances bypass stricter bank-level controls, aiding layering efforts.

• Mules can receive or send illicit funds across borders under their own names, masking the true criminal beneficiary.
• Minimal documentation beyond the mule’s identity conceals the origin of funds, complicating AML detection.
• Rapid cross-border movement of funds facilitates layering through multiple mule-managed channels.

• Mule recruiters instruct recruits to send or receive funds through remittance channels, often targeting cross-border corridors where institutional oversight can be challenging.
• Transaction references may cite bogus purposes (e.g., family support, freelance payments) to mask the true nature of these funds.
• Distributed transfers using multiple recruits hinder tracing the ultimate beneficiaries.

• After funds are deposited into a victim’s account, criminals instruct them to use remittance services to send money—often internationally—under the guise of processing business or customer payments.
• This method leverages the victim’s apparent innocence to disguise the criminals’ involvement and complicate law enforcement tracing.

• Victims are instructed to send funds through remittance services, enabling rapid cross-border transfers with limited oversight.
• By manipulating victims to keep transactions small or coded under personal reasons, scammers reduce scrutiny and exploit the victim’s emotional compliance.

• Recruits forward received funds via remittance or money transfer channels to criminals or third-party beneficiaries, often located abroad.
• Minimal documentation or lower transaction thresholds can help obscure the true origin and destination of these illicit proceeds.

• Allow cross-border fund movements that can hide the true beneficiary when compliance is circumvented.
• Sanctioned parties often route payments through multiple intermediaries to mask their involvement.

• Drug networks move profits quickly across multiple jurisdictions by sending smaller remittances to various recipients, avoiding large single transfers that draw scrutiny.
• These services enable layering by swiftly mixing illicit funds with legitimate transfers in international corridors that often have less robust oversight.

• Provide cross-border funds transfers through MSBs, enabling payments to precursor chemical suppliers in higher-risk jurisdictions without raising immediate red flags.
• Criminals often structure or split transactions across multiple senders or recipients to evade threshold triggers and obscure the money trail.

• Criminals deposit illicit proceeds from commodity trafficking in multiple, low-value transfers, making them appear as legitimate remittances.
• Cross-border capabilities facilitate rapid movement of funds, obscuring origin by layering transfers through various jurisdictions.

• Perpetrators posing as genuine owners of money mule or customer accounts use deepfake voice technology to pass call-based identity checks.
• Rapid cross-border transfers are initiated under false pretenses, leveraging realistic-sounding requests to evade suspicion.
• Deepfakes allow them to sidestep typical red flags, as staff believe they are speaking with the legitimate account holder.

• Fraudsters instruct victims to send initial 'advance fees' through common remittance providers, often under the pretext of urgent or unexpected fees.
• Once received, perpetrators rapidly withdraw or transfer the funds to additional accounts—potentially across multiple jurisdictions—to obscure the trail.

• Offenders segment or bundle government relief payouts into smaller remittance transfers, reducing visibility under certain thresholds.
• Cross-border remittances exploit varying degrees of regulatory oversight to mask the ultimate destination of fraudulent proceeds.

• Criminals instruct victims to send purported 'lottery fees' or 'taxes' via remittance operators, collecting payments in multiple locations to obscure their true identity.
• They layer or structure these funds across various jurisdictions, making tracing and recovery of victims’ money more difficult.

• Criminals split illicit funds into numerous small remittances, often evading more robust checks applied to larger transfers.
• Utilizing informal or lightly regulated corridors, they minimize record-keeping, making it challenging for authorities to trace or detect the illicit origin.

• Illicitly obtained tax refund proceeds can be rapidly transferred to offshore or high-risk jurisdictions, concealing their origin.
• Use of unregulated or informal channels within remittance services further complicates efforts to trace and recover fraudulent payouts.

• Criminals conducting piracy leverage these channels to move ransom funds across borders, often breaking down large sums into smaller amounts to avoid detection.
• In regions with lax oversight or informal transfer operators, documentation requirements are minimal, enabling pirates to obscure the origin of ransom proceeds.