Document Forgery

Document Forgery involves creating, fabricating, or altering paperwork (including financial records, identification, and contractual documents) to conceal or misrepresent key details about transactions, accounts, or individuals. Criminals exploit this technique to obscure ownership and the source of funds, produce fictitious business or personal identities, inflate invoice values, and falsify settlement records under the guise of legitimate operations. In practice, forged documents have been used to secure unauthorized bank disbursements and launder funds through multiple accounts, as shown in the “Turtle Island Resort” case where conspirators forged official records, obtained payments by virtue of those documents, and laundered illicit proceeds. Corrupt practitioners may also facilitate forgery to legitimize embezzlement schemes, as illustrated by bribed notaries fabricating official paperwork in Chen Shui-bian’s state fund scandal. In cross-border scenarios, forged documentation often appears in manipulated customs or shipping forms (e.g., misrepresented HS codes), enabling criminals to disguise suspicious flows across jurisdictions. In some instances, money launderers forge or alter identity documents to facilitate impersonation, shield or layer financial transactions, and thwart due diligence measures. By leveraging falsified records that appear authentic, criminals undermine standard oversight controls, disrupt compliance procedures, and complicate efforts to identify ultimate beneficiaries or detect the illicit origins of financial flows.

[
Code
T0012
]
[
Name
Document Forgery
]
[
Version
1.0
]
[
Parent Technique
]
[
Risk
Customer Risk, Product Risk
]
[
Created
2025-02-03
]
[
Modified
2025-04-02
]

Tactics

Forging or altering documentation obscures true ownership or fund origination by creating a misleading paper trail.

Risks

RS0001
|
Customer Risk
|

Document forgery enables criminals to fabricate or alter identity information, exploiting KYC processes that depend on the authenticity of customer-provided IDs and corporate filings. By submitting forged credentials, money launderers obscure true beneficial ownership and impersonate legitimate customers, undermining effective AML controls.

RS0002
|
Product Risk
|

Criminals leverage forged documents, such as shipping records, invoices, and financial statements, to bypass product-level due diligence controls that rely on authentic paperwork. By submitting falsified documentation to financial institutions or trade finance providers, they undermine verification and hide illicit flows under the guise of legitimate transactions. This represents the primary vulnerability exploited by document forgery.

Indicators

IND01118
|

Customer-submitted identification documents that appear to lack or have altered security features (e.g., missing holograms, irregular watermarks, or abnormal microprinting).

IND01119
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Bank statements, invoices, or other transactional records displaying signs of tampering such as erased details, misaligned figures, or handwritten corrections that differ from standard formats.

IND01120
|

Discrepancies in personal data (e.g., name, address, date of birth) between submitted documents and verified information from independent sources.

IND01121
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Documents containing unexplained formatting irregularities, such as inconsistent fonts, margins, or alignment issues that deviate from official templates.

IND01122
|

Repeated submission of suspicious documents across multiple transactions, displaying consistent signs of tampering or alteration.

IND01123
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Failure of automated document verification checks due to anomalies in document design elements (e.g., mismatched security features or invalid serial numbers).

IND01124
|

Submission of shipping or customs documentation with contradictory or tampered data (e.g., manipulated HS codes or declared commodity values) inconsistent with official trade records.

Data Sources

  • Includes official import/export filings, declarations, shipping routes, and commodity details.
  • Comparing these records with submitted shipping or customs documents helps identify tampering or misrepresentation in trade documents used to move illicit funds across borders.
  • Contains original invoice and contract details such as amounts, parties, and official references.
  • Comparing submitted documentation to these authentic records can reveal inflated or altered invoice data, signifying possible forgeries.

Provides official legal documents such as notarized deeds, court orders, and judgments. Cross-referencing these documents with submitted records helps detect forgery or fabrication, especially when criminals alter or counterfeit legal papers to legitimize financial transactions or misrepresent ownership and obligations.

  • Aggregated public and official information about individuals and entities includes identity details, legal status, and beneficial ownership data.
  • Cross-referencing submitted personal or corporate documentation against these records helps uncover inconsistencies or evidence of forged identities or misrepresented details.
  • Centralized platforms store and track versions of financial and identification documents.
  • Audit trails and version histories enable the detection of unauthorized alterations or suspicious modifications consistent with document forgery techniques.
  • Specialized systems or services authenticate security features, design elements, and embedded data on official identification documents.
  • They detect anomalies in passports, IDs, or other paperwork, indicating forgery or alteration, which is crucial for uncovering falsified identities or misrepresented information.
  • Involves bills of lading, shipping logs, and certificates of origin that describe goods, valuations, and transit routes.
  • Matching these with provided shipping paperwork highlights inconsistencies or manipulated entries, indicating document forgery in trade-based laundering schemes.
  • Contains verified identity and business profiles, addresses, beneficial ownership data, and risk metrics used to confirm the authenticity of submitted documentation.
  • Cross-referencing newly provided documents with established KYC information helps uncover inconsistencies indicative of potential forgeries.
  • Contains official data on company registration, shareholders, directors, and beneficial owners.
  • By verifying corporate documentation against these registries, institutions can uncover forged or misrepresented corporate structures used to mask the true owners of illicit transactions.

Mitigations

For higher-risk customers or suspicious documentation, employ forensic document examination techniques and direct verification with issuing authorities. Verify notarial seals, official stamps, and reference numbers in supporting records to detect tampering or fabrication, mitigating advanced forgery risks in complex or high-value scenarios.

Implement robust checks and automated solutions to verify official identity documents, cross-referencing personal details with governmental databases or reliable third-party sources. Confirm the authenticity of submitted documents by examining security elements (e.g., holograms, watermarks) or scanning for signs of alteration, preventing criminals from using forged identification or business paperwork.

Equip frontline and compliance teams with specialized training to recognize tampered documentation, such as mismatched fonts, missing security features, or altered seals. Provide samples of common forgeries and hands-on testing to ensure staff can swiftly identify suspect materials and escalate them for specialized review.

Conduct thorough pre-employment and periodic checks, especially for roles handling sensitive documentation (e.g., notaries, compliance reviewers), to identify past involvement in fraud or forgery. This reduces insider collusion risks and curtails corrupt practitioners from facilitating forged records.

Cross-check details in customer-provided paperwork with independent public registries, authoritative databases, and open-source intelligence to validate authenticity. Look for inconsistencies in corporate registration data, licensing details, or professional credentials that could indicate forged or altered documents.

Scrutinize trade, shipping, and customs documents for inconsistencies or suspicious edits. Verify declared HS codes, commodity values, and shipment details against official data or market references. Investigate misaligned or obviously altered entries that could represent forged paperwork concealing illicit trade flows.

Instruments

IN0004
|
|
  • By altering payee information, amounts, or signatures on checks, criminals can fabricate legitimate-looking payments from forged documents.
  • This technique secures unauthorized disbursements from accounts, allowing launderers to transfer and integrate illicit proceeds under the guise of routine transactions.
  • Criminals use forged personal or corporate identification documents to open accounts in fictitious names or with misrepresented entities, bypassing standard KYC checks.
  • They may submit falsified bank statements or references to mask illicit inflows, making suspicious transactions appear legitimate and hindering compliance oversight.
  • Forged shipping and export documents (e.g., bills of lading) are submitted to trigger payments under letters of credit.
  • By misrepresenting the nature, value, or existence of shipped goods, criminals legitimize cross-border fund movements and obscure illicit origins.
  • Forged trust deeds or beneficiary lists obscure the real parties entitled to trust assets.
  • By altering or fabricating these records, criminals transfer or window-dress illicit sums within a trust structure, thwarting routine AML scrutiny of genuine ownership.
  • Criminals create fictitious or inflated invoices with forged vendor details and line items, justifying large fund transfers that appear as valid business transactions.
  • These counterfeit documents obscure the true source of funds, allowing launderers to integrate illicit proceeds into legitimate billing workflows undetected.
  • Criminals falsify corporate formation documents or shareholder registries to mask the true owners behind an entity.
  • Through forged filings, they conceal beneficial ownership and inject illicit funds into a company’s capital structure, complicating regulatory attempts to trace the source.

Service & Products

  • Introduction of fabricated or altered invoices into the billing workflow to inflate transaction values or create fictitious payees.
  • Erased or overwritten invoice details conceal actual beneficiaries and shield the trail of illicit proceeds.
  • Falsified shipping manifests or customs declarations mask actual contents or misstate shipment values, concealing suspicious flows.
  • Use of counterfeit bills of lading and related documents facilitates the movement of illicit funds under the guise of legitimate cargo.
  • Bribed or complicit notaries authenticate forged legal and financial documents, granting an appearance of legitimacy.
  • Notarized forgeries bypass due diligence controls, making it harder to trace ultimate beneficiaries or question document validity.
  • Unscrupulous legal practitioners can draft or certify documents known to be forged, enabling criminals to legitimize falsified claims or transactions.
  • Forged legal frameworks and contracts obscure actual parties to a deal, complicating investigations into beneficial ownership.
  • Manipulation of customs and shipping forms, including HS codes, to disguise cargo contents or real trade values.
  • Counterfeit bills of lading or certificates of origin permit false cross-border transactions and conceal illicit funds.
  • Presentation of forged bills of lading or export documents to trigger payouts under letters of credit or documentary collections.
  • Submission of counterfeit shipping or insurance records to mask the true nature and value of goods, complicating AML checks.
  • Use of forged incorporation or identification documents to open accounts under fictitious or misrepresented entities, bypassing due diligence.
  • Altered financial statements or references conceal illicit inflows and mask fraudulent activity.
  • Use of forged personal identification documents to open accounts under false identities, evading standard KYC requirements.
  • Manipulated bank statements appear legitimate, helping criminals move illicit proceeds without immediate detection.
  • Creation or alteration of official paperwork (e.g., IDs, financial records, contracts) to misrepresent ownership or transaction details.
  • Criminals exploit professional document services to produce convincing forgeries that bypass typical verification procedures.
  • Submission of counterfeit or inflated invoices to secure credit or advance payments from lenders.
  • Forged vendor details and invoice amounts disguise the origin of funds and magnify opportunities for laundering.
  • Criminals submit falsified financial statements or audits to misrepresent business performance and hide corrupt revenue streams.
  • Altered or incomplete transaction records obscure true fund sources and shift suspicion away from illicit activities.
  • Falsification of incorporation documents and corporate filings to conceal actual ownership and control of entities.
  • Forged board resolutions or shareholder agreements facilitate unauthorized asset transfers without immediate detection.

Actors

  • Engages in forging or procuring falsified documents (e.g., counterfeit IDs, bank records) to support layering or integration tactics.
  • Presents these forged materials to financial institutions to evade standard monitoring and obscure beneficial ownership, frustrating attempts to trace illicit proceeds.
  • Produces or alters official documents, such as identification, financial statements, or corporate filings, at the request of criminals seeking to obscure ownership or transaction details.
  • Undermines financial institutions’ due diligence and KYC processes, as forged paperwork can appear authentic and bypass routine checks, masking the movement of illicit funds.
  • Corrupt or bribed lawyers and notaries authenticate or certify forged documents, lending apparent legitimacy to falsified claims or identities.
  • This exploitation of legal credentials complicates financial institutions' verification procedures and fosters an environment where forged paperwork can pass initial scrutiny.

References

  1. APG (Asia Pacific Group on Money Laundering). (2016, September). APG Typologies Report on Fraud & Money Laundering in the Pacific.APG Secretariat. https://apgml.org/documents/default.aspx

  2. APG (Asia/Pacific Group on Money Laundering). (2009). APG yearly typologies report 2009. Asia/Pacific Group on Money Laundering (APG). https://apgml.org/documents/default.aspx

  3. Keatinge, T., Saiz, G. (2023). Euro SIFMANet: The role of data in sanctions implementation. Royal United Services Institute for Defence and Security Studies. https://static.rusi.org/446-CR-Barcelona-sanctions-final-web.pdf

  4. Saiz, G., Reimer, S. (2023, May). Missing connections: Crime-enabled terrorism financing in Europe. Royal United Services Institute for Defence and Security Studies.https://rusieurope.eu/ova_doc/missing-connections-crime-enabled-terrorism-financing-in-europe/