Placement

Placement is the first moment illicit proceeds are accepted as legitimate. The criminal exchanges dirty cash, crypto, or assets for anything the market treats as normal: a deposit balance, casino chips, prepaid cloud-compute credits, bulk fuel, raw materials, or any other entitlement the criminal can still control. Acceptance may come from a bank, an MSB, a utility company, a data-center, a shipping line, or a front enterprise—the common denominator is that the counterparty books the transaction as routine commerce, and the payment now sits inside the legal economy’s books. The primary objective is to turn suspicion into paperwork: an invoice, a receipt, or an account entry that portrays the funds as ordinary business activity. Placement is typically the most vulnerable stage for criminals, as unusual transactions, mismatches in customer profiles, or high-risk counterparties can trigger detection.

[
Matrix
Money Laundering
]
[
Name
Placement
]
[
Version
1.0
]
[
Created
2025-01-22
]
[
Modified
2025-05-21
]

Techniques Under This Tactic

Cash deposits are a primary method for introducing illicit funds into the formal banking system, often by structuring deposits just below reporting thresholds. This technique reduces the immediate detection risk by merging criminal proceeds with legitimate accounts at the earliest stage of laundering.

Mules often deposit or transfer illicit proceeds into legitimate channels, effectively integrating the funds into the financial system.

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By employing a mule to feed illicit cash into cryptocurrency via ATMs, criminals achieve the placement stage by converting physical currency into digital assets that are harder to trace.

Illicit cash is funneled through casino transactions by buying chips, engaging in minimal wagering, and rapidly redeeming them to insert criminal proceeds surreptitiously into the financial system. Distributing deposits across multiple mules and thresholds avoids triggering standard cash-reporting requirements, making this the primary objective of the technique.

Illicit cash can be introduced into the hawala network at the initial stage.

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Using Daigou to initially introduce illicit cash into the formal economy by purchasing goods abroad.

A front company, by its very nature of conducting ostensible business, inherently provides necessary cover to absorb and disguise the origin of criminal proceeds at their point of entry.

Structuring introduces illicit funds into the financial system in sub-threshold increments, explicitly avoiding mandatory reporting triggers and reducing initial detection risks at the placement stage.

Micro-structuring explicitly introduces illicit funds into legitimate financial channels by splitting larger sums into many sub-threshold deposits, bypassing reporting requirements and minimizing detection risk. This aligns with the placement objective, as it facilitates the initial infiltration of criminal proceeds while keeping each transaction under the regulatory radar.

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Criminals infiltrate bank accounts by blending illicit funds with expected legitimate remittances, thereby introducing criminal proceeds into the financial system under the guise of routine inbound transfers. This is the primary objective of cuckoo smurfing.

Money remittance splitting is used to introduce illicit funds into the financial system by keeping individual transfers below reporting thresholds and dispersing them under various sender identities. This reduces the direct detection risk as the proceeds enter legitimate channels.

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Frequent, sub-threshold ATM deposits systematically introduce illicit cash into the financial system, effectively completing the initial infiltration of criminal proceeds while reducing the immediate risk of detection.

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Smurfing involves breaking down large sums of illicit funds into multiple small transactions that are explicitly below reporting thresholds. This tactic facilitates the initial entry of criminal proceeds into the legitimate financial system with a reduced risk of detection.

Criminals distribute illicit cash deposits in smaller amounts across multiple branches or institutions, introducing proceeds into the financial system while avoiding detection through threshold-based reporting and localized scrutiny. This technique constitutes an early-stage infiltration of illicit funds.

Criminals introduce illicit cash into gaming machines as an initial infiltration of funds, converting physical currency into TITO tickets that appear to be legitimate gambling proceeds. This tactic reduces detection risk by merging illegal cash with normal gaming activities.

Crypto ATMs allow criminals to convert physical cash into cryptocurrency with minimal oversight, effectively introducing illicit funds into the financial system as an initial infiltration step.

Criminals may directly deposit cash or fiat, potentially in small increments, into an online game or metaverse platform using methods such as credit card, PayPal, or crypto on-ramps as an initial infiltration route.

Criminals use stolen or unverified payment methods or deposit cryptocurrency to acquire in-game assets or currency, introducing illicit funds into a seemingly legitimate gaming ecosystem where detection controls may be weak or nonexistent.

Once produced, counterfeit notes are blended with genuine cash transactions, often in smaller deposits or cash-intensive businesses, to minimize detection. This process introduces illicit funds into legitimate financial channels.

Criminals physically or electronically introduce illicit funds into gambling channels, converting raw cash or electronic balances into recorded bets or chips as the initial infiltration step of the laundering process.

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The technique involves using illicit funds to purchase lottery tickets, effectively introducing these funds into the financial system as legitimate transactions under the guise of lottery ticket purchases.

Illicit funds are introduced into the betting system at the shop level, disguising large amounts of cash as routine wagers.

Criminals exchange illicit cash for casino chips or credits, thereby introducing those criminal proceeds into the financial environment under the guise of legitimate gambling returns. This initial conversion of illegal funds reduces the immediate detection risk by masking them as part of normal casino transactions.

Criminals purchase official negotiable instruments (e.g., cashier’s checks, traveler’s checks) with illicit cash as an initial infiltration step, ensuring the currency enters the financial system with fewer suspicions compared to direct large cash deposits.

Remote deposit capture primarily facilitates the initial introduction of illicit funds into financial channels by allowing criminals to deposit checks or money orders from remote locations. This bypasses physical branch scrutiny and merges proceeds with legitimate transactions.

Ultimately aims to introduce large volumes of criminal proceeds into the financial system through smaller, less alarming deposits.

Criminals deposit illicit proceeds into cooperative or mutual institutions as an initial infiltration into the financial system. They leverage membership-based models and minimal documentation requirements to pass early KYC hurdles.

Alternative payment channels can also serve as an initial entry point for inserting illicit funds into the financial system. These funds are transformed into prepaid cards, cryptocurrencies, or mobile remittance balances under weak oversight.

Undeclared earnings are introduced into legitimate financial channels by intermingling illicit inflows with otherwise normal revenues and then depositing them into personal or business accounts. This disguises criminal proceeds as ordinary operating income, thereby reducing immediate detection risks.