In access facilitation, adversaries strategically prepare secure and dependable entry points into financial or quasi-financial environments. This preparatory stage ensures that when illicit funds are ready to enter the broader financial ecosystem, they encounter minimal scrutiny and little resistance. Rather than focusing on the placement or movement of funds, the emphasis here is on proactively building or exploiting relationships, creating networks of complicit actors, or gaining privileged access to platforms and institutions. Such groundwork significantly reduces the effectiveness of standard AML defenses, as it ensures illicit funds enter under the guise of legitimate activity. Detection at this stage involves identifying anomalies during onboarding processes, overly lenient acceptance of high-risk customers, or suspicious networks involving the same facilitators or intermediaries.
Access Facilitation
Techniques Under This Tactic
Criminals bribe insiders to circumvent KYC and compliance checks, allowing them to open or maintain financial accounts with reduced scrutiny and gain entry into legitimate financial channels.
Criminals use money mule accounts to bypass standard KYC/AML checks, establishing entry points into the financial system without revealing the ultimate controllers of illicit funds. This serves as a secondary objective when enlisting third-party account holders.
Criminals exploit the minimal or nonexistent AML/KYC checks of certain crypto ATM operators as a convenient entry point into the crypto ecosystem, circumventing standard due diligence and gaining rapid access to less-regulated channels.
IVTS explicitly bypasses formal bank oversight and circumvents KYC requirements by relying on personal trust-based or off-record paths, providing criminals with unregulated entry points to move illicit funds across borders. The primary objective behind using IVTS is to avoid standard AML controls in official financial channels.
Unlicensed MSBs enable criminals to bypass standard licensing and KYC requirements, providing a direct or less-regulated channel to exchange or remit illicit funds. This lowers entry barriers into financial systems, making it a primary strategic objective for the rapid, under-the-radar movement of proceeds.
Hot Transfers rely on offsetting accounts and barter-like commodity exchanges to circumvent formal KYC requirements and bypass bank-led transaction monitoring. This provides criminals with a direct entry point into less-regulated financial flows.
Hawala bypasses formal banking channels and standard KYC requirements by leveraging personal trust networks and off-record transactions. This provides criminals with a direct entry point for illicit funds into less-regulated financial flows.
Complicit insiders undermine institutional AML controls from within, bypassing KYC checks and normal oversight, allowing criminals to deposit and transfer illicit funds with minimal scrutiny. This creates a direct entry point into the financial system and circumvents standard compliance protocols.
Through forged, stolen, or synthetic identities, criminals bypass KYC and negative screening controls to open or maintain accounts with minimal scrutiny, directly enabling entry into financial systems for laundering proceeds. This constitutes the primary objective of identity manipulation.
Criminals use forged, altered, or stolen identification documents to circumvent KYC and CDD checks, enabling them to open or maintain accounts under false or impersonated identities. This grants illicit access to financial services by bypassing standard due diligence controls and effectively concealing their true identity at the onboarding stage.
Launderers proactively adjust their names so onboarding and screening controls treat them as low-risk new customers, thereby preparing secure and dependable entry points into financial environments.
By leveraging multiple passports or nationalities, criminals can circumvent KYC and identity verification barriers under different personas, enabling easier access to financial services without triggering standard or enhanced due diligence measures.
By acquiring new passports or residencies through CBI/RBI programs, criminals can explicitly circumvent stricter KYC checks tied to their true backgrounds. Presenting ostensibly legitimate documentation lowers scrutiny when opening accounts or transacting across borders, thereby streamlining entry into financial systems under an alternate legal identity.
By positioning the proxy as the formal account holder, criminals can bypass KYC barriers and exploit weak ongoing due diligence. This allows them to secure or maintain financial access that would likely be denied if the true owner were revealed.
By falsely labeling illicit proceeds as gifts, charitable donations, or other benign payments, criminals bypass standard due diligence and scrutiny. This misrepresentation allows them to open accounts, transfer funds, or conduct other banking activities without triggering red flags, effectively securing entry and continued access to financial systems.
By labeling remittances as gifts, familial support, or charitable donations, criminals circumvent standard AML triggers and inquiries, effectively securing entry or continued use of remittance channels with minimal scrutiny for illicit funds.
By exploiting minimal AML oversight and weak KYC requirements in certain jurisdictions, criminals find entry points into the global financial system, thereby circumventing stricter controls in more regulated markets.
Criminals deliberately exploit minimal KYC or use forged IDs to open offshore e-wallet or prepaid card accounts, circumventing AML controls and establishing a discreet entry point into the financial system. This is a core objective because it enables them to bypass standard customer due diligence requirements from the outset.
Offshore gambling licenses, often obtained in loosely regulated jurisdictions, provide criminals with readily accessible channels for depositing, transferring, and withdrawing illicit funds under the guise of gaming activities, thereby fulfilling the goal of access facilitation.
In "Virtual Worlds," criminals leverage pseudonymous accounts on gaming or exchange platforms, effectively bypassing conventional AML scrutiny, such as using decentralized exchanges linked to metaverse NFTs.
Identity impersonation is primarily used to bypass KYC/AML checks, secure banking services, and exploit existing accounts under false identities, creating entry points for laundering activities.
Remote identity deception enables criminals to open accounts or services under false, stolen, or synthetic identities, bypassing standard KYC controls. By exploiting lax or purely online onboarding processes, they gain entry into financial systems, facilitating illicit fund flows.
By compromising legitimate customer accounts, criminals bypass standard KYC and AML checks, gaining direct usage rights under an established profile. This serves as the primary objective, securing unhindered entry into the financial system for subsequent laundering activities.
Criminals deliberately secure or retain complicit Money Service Business (MSB) channels to bypass genuine oversight, enabling illicit funds to flow under the guise of standard money services without triggering AML controls. This is the primary objective, as it grants direct access to financial systems while subverting compliance mechanisms.
Criminals exploit loosely regulated rotating savings and credit associations (ROSCAs) or similar informal micro-finance schemes as low-barrier financial entry points, circumventing standard KYC and AML controls. By pooling illicit funds with legitimate member contributions, they evade scrutiny at the initial deposit stage and obscure the true source of the money.
By controlling or subverting the bank's leadership, criminals can bypass standard AML checks for account creation and transaction monitoring.
Criminals exploit the minimal due diligence performed by respondent banks to establish frictionless entry points into the international financial system. This allows them to explicitly circumvent stricter compliance controls at the correspondent institution and bypass standard AML checks.
Criminals exploit sub-agents and third-party payment processors under a licensed umbrella to circumvent stricter AML/CFT checks. They leverage weaker oversight at the agent or sub-agent level to covertly introduce or move funds into the financial system.
By channeling transactions through loosely supervised sub-agents operating under a licensed payment institution, criminals can bypass stricter KYC/AML checks and gain easier entry into the financial system.
Criminals exploit lax KYC procedures and complicit currency exchange operators to circumvent AML measures, thereby securing entry into or continued use of financial channels despite suspicious transaction patterns or threshold violations.
Unlicensed brokers facilitate launderers' entry into real estate transactions by circumventing regulated AML checks, effectively bypassing KYC and suspicious activity reporting requirements. The primary objective is to secure property purchase or sale channels with minimal scrutiny.
Criminals exploit informal or minimally regulated payment channels to bypass stricter KYC and AML regimes. This enables them to access financial services that would otherwise be denied and allows illicit proceeds to flow with minimal oversight.
By subverting remote KYC or ID verification steps, criminals ensure accounts remain open or accessible with minimal legitimate identification. This directly exploits procedural gaps to bypass digital onboarding checks.
Criminals recruit money mules to explicitly circumvent KYC and compliance barriers, using third-party account credentials to establish covert entry points into financial systems and reduce direct exposure.
Criminals leverage social media to recruit unwitting or complicit money mules, circumventing typical KYC and compliance measures by gaining access to their personal bank accounts. This tactic primarily establishes new entry points into the financial system for illicit funds.
Phishing mule recruitment primarily aims to bypass standard AML controls by tricking victims into revealing information or opening accounts that criminals can directly use to move illicit funds. It exploits trust and confusion to gain access to legitimate financial channels.
Through deceptive romantic relationships, recruiters gain victims' willing cooperation to use personal or business accounts, effectively bypassing standard KYC and AML checks. This is the primary strategic objective, as it opens new channels to move illicit funds under less scrutiny.
Criminals exploit the personal bank accounts of unsuspecting recruits under the guise of legitimate employment. This allows them to bypass standard KYC measures and gain a direct channel into regulated financial systems with minimal scrutiny.