Criminals establish multiple shell companies and other corporate vehicles across different jurisdictions to disguise the real owners and reduce scrutiny. They frequently combine corporate formations with trusts or other legal arrangements in secrecy-friendly jurisdictions, creating multi-layered structures that appear legitimate yet obstruct asset tracing and law enforcement efforts. By leveraging variations in AML requirements and deploying nominee shareholders or directors, these networks impede effective KYC checks and regulatory oversight, especially when transactions cross multiple jurisdictions with differing transparency standards. Such arrangements also attract unsuspecting external investors unaware of the illicit origins of funds, further complicating investigations and recoveries.
Multi-Jurisdiction Corporate Structures
Tactics
Multi-jurisdiction corporate formations primarily serve to obscure beneficial ownership behind layered shell entities and trusts, thwarting transparent asset tracing and law enforcement inquiries.
Risks
By layering complex corporate vehicles and employing nominee directors or shareholders, criminals conceal true beneficial ownership and undermine KYC processes. This creates significant opacity around customer identity and ownership structures, frustrating due diligence efforts.
Criminals exploit lax or differing AML standards across multiple jurisdictions and secrecy-friendly regions to evade robust KYC measures. By registering and operating shell entities in these locations, they leverage legal and regulatory gaps to obscure beneficial ownership and reduce transparency, making it the central vulnerability in this technique.
Indicators
Frequent establishment of new legal entities across multiple jurisdictions with disparate regulatory environments in short time frames.
Complex ownership structures spanning multiple jurisdictions, involving layers of legal entities that obscure the ultimate beneficial owner.
Use of shell companies with no physical presence or employees in the jurisdictions where they are registered to conduct significant financial transactions.
Transactions involving entities based in jurisdictions with known weak regulatory frameworks or high levels of secrecy.
Frequent changes in company directors or beneficial owners across different jurisdictions without a clear business rationale.
Entities whose financial transactions are inconsistent with their stated business activities or industry norms, indicating a mismatch or discrepancy.
Use of intermediary entities with no apparent legitimate business function to facilitate transactions between parties in high-risk jurisdictions.
Involvement of professional intermediaries (e.g., lawyers, accountants, or corporate service providers) known for establishing complex multi-jurisdictional corporate structures.
Unusual patterns of fund movement through multiple legal entities across different jurisdictions in rapid succession.
Entities conducting transactions lacking a documented or logical economic rationale.
Missing or contradictory beneficial ownership information for entities involved in cross-jurisdictional transactions.
Multiple layering transactions across jurisdictions that obscure the origin and final beneficiary of funds.
Frequent changes in an entity’s registered address across multiple jurisdictions with no clear business justification.
Unusual volume or frequency of inter-company loans or transfers between related entities across different jurisdictions with minimal supporting documentation.
Use of nominee directors or shareholders with no direct involvement in company operations, particularly across multiple jurisdictions.
Data Sources
- Consolidates negative news, lawsuits, and regulatory actions against individuals or entities.
- May reveal known involvement of professional facilitators setting up complex, multi-jurisdictional corporate structures.
- Helps identify higher-risk corporate formations or ongoing legal proceedings tied to money laundering activity.
- Identifies regulatory weaknesses and levels of secrecy in various jurisdictions.
- Highlights high-risk or offshore locations commonly exploited to create multi-layered corporate entities.
- Assists investigators in prioritizing cross-border flows for enhanced scrutiny.
- Provides comprehensive details on trust structures, including beneficiaries, trustees, associated financial accounts, and transaction histories.
- Helps uncover hidden beneficial ownership or multi-layered corporate vehicles used in multi-jurisdiction arrangements.
- Cross-referencing trust documents (e.g., balance sheets, tax returns) with corporate filings can reveal unexplained ownership patterns or suspicious relationships.
- Contains formal agreements and invoices supporting inter-company transactions.
- Helps verify whether cross-border transfers between related entities are backed by legitimate documentation.
- Detects non-existent or inflated contracts often used to justify illicit fund flows in layered corporate networks.
- Records cross-border and domestic fund flows, including timestamps, amounts, and involved accounts.
- Identifies rapid layering transactions and complex routing through multiple corporate entities.
- Correlates transaction patterns with corporate structures to spot suspicious multi-jurisdictional behavior.
- Aggregates public data on individuals and entities, including addresses, incorporation records, and prior directorships.
- Supports cross-checking of suspicious corporate formations or frequent changes in registration details across borders.
- Helps trace potential shell or front companies used in multi-jurisdiction laundering networks.
- Documents reported business activities, revenue sources, and operational footprints.
- Enables comparison between declared operations and actual cross-jurisdiction transactions.
- Aids in detecting shell or dormant companies lacking legitimate activity in multi-layered structures.
- Contains verified identities, addresses, and beneficial ownership details for individuals and entities.
- Helps detect nominee directors or layering tactics across different jurisdictions.
- Comparing declared ownership against registry data can expose inconsistencies indicative of multi-jurisdiction laundering schemes.
- Provides official registration information, directors, shareholders, and beneficial ownership structures across jurisdictions.
- Uncovers layered corporate vehicles or nominee arrangements used to obscure true owners in multi-jurisdiction setups.
- Cross-referencing registry details with trust or KYC records can highlight hidden relationships and suspicious ownership changes.
Mitigations
Adopt a granular country risk framework that flags secrecy-friendly or weakly regulated jurisdictions often used in multi-jurisdiction corporate structures. Assign higher risk ratings to entities or transactions tied to these locations, triggering escalated scrutiny for cross-border transfers and beneficial ownership transparency. This measure addresses the exploitation of diverging AML standards between jurisdictions.
Perform advanced checks on complex multi-jurisdictional corporate structures by cross-referencing registration details, beneficial owners, and directorship changes in public and overseas registries. Confirm any nominee shareholders or trustees involved by verifying their roles and ensuring consistency across layers of ownership. This measure targets layered concealment by exposing undisclosed or inconsistent ownership records.
Implement comprehensive Customer Due Diligence (CDD) measures for corporate structures operating across multiple jurisdictions by collecting and validating official formation documents, beneficial ownership data, and relevant licenses from each jurisdiction involved. This measure directly addresses layering vulnerabilities by mapping out all owners across different regions, preventing undisclosed beneficial interests.
Implement specialized monitoring rules to detect unusual patterns in inter-company loans, cross-border transfers, and rapid capital flows among corporate entities in different jurisdictions. By focusing on sudden spikes in multi-jurisdictional movement or convoluted layering routes, institutions can identify suspicious transfers linked to hidden beneficial owners.
Require rigorous oversight of lawyers, corporate service providers, and other intermediaries who form and manage multi-jurisdictional corporate structures. Institutions should conduct targeted due diligence on these third parties, checking for patterns of enabling hidden or overlapping beneficial owners, thereby reducing susceptibility to professional enablers of illicit layering.
Leverage open-source intelligence (OSINT), corporate registries, and external databases in each relevant jurisdiction to validate declared ownership and identify contradictory filings. By comparing internally gathered information with verified external sources, institutions can detect undisclosed ultimate beneficiaries and nominee directorships that facilitate multi-jurisdiction layering.
Collaborate proactively with peer financial institutions, regulators, and, where permissible, law enforcement to pool data on beneficial ownership and cross-jurisdictional corporate linkages. Such collaboration highlights entities that exploit differing AML standards across multiple jurisdictions, enabling a coordinated response to dismantle illicit corporate layering.
Restrict or condition services—such as account opening or cross-border payment processing—if a customer’s multi-jurisdictional structure lacks transparent ownership details or exhibits unexplained layers. By curtailing higher-risk services until ownership clarity is achieved, institutions deter the exploitation of complex corporate arrangements for illicit purposes.
Continuously re-verify corporate ownership structures and monitor changes in directors or beneficial owners across multiple jurisdictions. This measure ensures that evolving multi-jurisdictional entities do not escape detection by reshuffling ownership layers or relocating to less transparent regions, allowing institutions to reassess risk in near real-time.
Instruments
- Criminals establish bank accounts under shell companies or layered corporate entities across different jurisdictions to funnel and obscure illicit proceeds.
- Variations in AML/KYC requirements among multiple countries allow opening accounts with minimal scrutiny, facilitating complex layering and movement of funds under the guise of legitimate corporate transactions.
- Multi-jurisdictional shell companies or trusts purchase real property, channeling large sums under ostensibly legitimate investments.
- Varying property registration and disclosure rules across regions conceal the true owners, enabling significant asset integration without transparent traces.
- Criminals interpose trusts in multiple jurisdictions, designating nominee trustees to shield the ultimate owners from visibility.
- These layered trusts hide the trail of control over assets, allowing the architects to manage illicit funds with impunity.
- Bearer shares enable possession-based ownership of corporate entities, removing the traditional share registry connection to beneficial owners.
- By incorporating in jurisdictions that allow bearer shares, criminals can seamlessly transfer control to new holders without creating transparent ownership records.
- Criminals distribute or subdivide ownership stakes across several corporate vehicles registered in secrecy-friendly jurisdictions.
- Nominee shareholders and directors are appointed to conceal the true beneficial owners, significantly complicating KYC and regulatory checks.
Service & Products
- Provides a nominal physical address and corporate presence in multiple jurisdictions without an actual operational footprint.
- Criminals leverage these services to add credibility and complicate investigations, as official records show multiple addresses with no real activity.
- Lawyers can craft complex legal arrangements and contracts that legitimize layered corporate structures in multiple jurisdictions.
- Exploits regulatory gaps to obscure beneficial ownership, complicating KYC processes and authorization checks.
- Offshore accounts introduce an additional layer of secrecy by operating under less rigorous AML requirements in certain jurisdictions.
- Criminals exploit these accounts to route illicit proceeds globally, hampering efforts to identify and freeze assets.
- Professionals can produce and manage financial statements for shell companies across jurisdictions, masking the true flow of illicit funds.
- Manipulated or opaque accounting records conceal ultimate beneficial owners and obscure suspicious transactions.
- Allows criminals to move funds internationally through intermediary banks, reducing transparency regarding the ultimate beneficial owners.
- Varying AML standards between correspondent banks can shield the multi-layered corporate structure from thorough due diligence and detection.
- Enables the formation of corporate entities in secrecy-friendly or lightly regulated jurisdictions, hindering disclosure of beneficial owners.
- Facilitates rapid setup of interlinked offshore structures that frustrate law enforcement and AML investigations.
- Facilitates the establishment and administration of multiple corporate entities and trusts across different jurisdictions, enabling criminals to layer ownership and conceal their identities.
- Providers may offer nominee director or shareholder services, further obscuring beneficial ownership from regulators and financial institutions.
Actors
Correspondent banks handle cross-border fund transfers for entities in multiple jurisdictions by:
- Providing indirect access to foreign financial systems where AML standards vary.
- Facilitating the international movement of funds that can cloak the origin and destination of illicit proceeds.
Criminal actors rely on these intermediary channels to complicate KYC and regulatory scrutiny.
Unwitting investors may inject legitimate capital into multi-jurisdictional corporate networks by:
- Funding ventures without realizing the underlying structures are designed to launder illicit proceeds.
- Adding a layer of apparent legitimacy that mixes illicit funds with genuine investments.
This complicates asset tracing and investigations for financial institutions.
Operating under lighter or less transparent AML regimes, these institutions:
- Maintain accounts for layered corporate structures, shielding beneficial owners from scrutiny.
- Enable rapid cross-border transfers that bypass rigorous oversight.
Criminals use such offshore platforms to conceal illicit assets and impede investigative efforts.
These providers create and manage corporate entities across multiple jurisdictions by:
- Handling entity formation, registered addresses, and administration services.
- Offering nominee director or shareholder arrangements that veil beneficial owners.
Criminals exploit such services to layer funds and reduce transparency, impeding financial institution due diligence.
Accountants and auditors produce and maintain financial records for entities spanning multiple jurisdictions by:
- Creating or reviewing statements that merge illicit funds with legitimate capital, minimizing red flags.
- Completing filings that omit or obscure ultimate beneficial owners.
Their professional involvement imparts legitimacy, hindering financial institutions' ability to detect suspicious flows.
Criminals use various entities—including shell or front companies, offshore vehicles, and private interest foundations—to:
- Build complex, multi-layered structures that obscure true control and ownership across multiple jurisdictions.
- Exploit secrecy-friendly regions and minimal disclosure rules, hampering law enforcement tracing efforts.
- Merge legitimate and illicit funds, complicating financial institutions’ KYC and transaction monitoring processes.
These networks orchestrate multi-jurisdictional corporate structures by:
- Forming and interlinking shell entities across secrecy-friendly jurisdictions to obscure beneficial ownership.
- Coordinating with legal, accounting, and corporate service professionals to ensure minimal transparency.
They deploy nominee shareholders or directors to mask criminal control and hinder financial institutions’ KYC checks.
Nominees serve as registered directors or shareholders in multiple jurisdictions, concealing the true beneficial owners. They:
- Appear in official records, replacing the actual controllers of corporate structures.
- Often act at the instruction of laundering networks, knowingly or unknowingly aiding the layering process.
This tactic frustrates KYC and investigations by placing nominal figures in key ownership roles.
Legal professionals facilitate multi-jurisdictional corporate structures by:
- Drafting incorporation documents and contractual arrangements tailored to exploit regulatory gaps.
- Advising on residency, trust, or corporate formation strategies that limit beneficial ownership disclosure.
Their expertise can be knowingly or unwittingly misused to legitimize layered entities and obscure criminal proceeds.
References
FATF (Financial Action Task Force). (2023, March). Guidance on beneficial ownership of legal persons. FATF. http://www.fatf-gafi.org/publications/FATFrecommendations/guidance-beneficial-ownership-legal-persons.html
Financial Action Task Force (FATF). (2006). The misuse of corporate vehicles, including trust and company service providers. FATF. https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Misuse%20of%20Corporate%20Vehicles%20including%20Trusts%20and%20Company%20Services%20Providers.pdf.coredownload.inline.pdf