Criminals conduct or facilitate illicit financial activities over public WiFi hotspots—such as in cafes, hotels, or airports—to mask physical location and user identity. These open networks typically have weaker security measures and minimal user verification, allowing adversaries to bypass AML controls that rely on IP-based risk scoring or device fingerprinting. Additionally, criminals often combine public hotspots with anonymity tools such as VPNs or Tor to further conceal their true IP addresses and degrade investigative leads. These measures severely complicate attribution, as multiple users may share the same public IP address while generating numerous high-risk transactions, frustrating efforts to identify and link specific individuals to illicit fund movements.
Public WiFi Networks
Exploitation of Public WiFi Networks
Tactics
Criminals exploit public WiFi hotspots to obscure user identity and location, undermining IP-based AML controls and complicating digital forensics. By blending in with multiple transient users on the same network, they significantly reduce attribution risk, aligning this technique primarily with evasion and operational security goals.
Risks
Criminals exploit open-access public WiFi networks as a primary vulnerability due to the lack of robust user identification or authentication. By leveraging shared or transient IP addresses, they can mask their identities, bypass IP-based AML controls, and complicate investigative efforts, making it challenging to link suspicious transactions to specific individuals.
Indicators
Use of VPNs in conjunction with public WiFi access, as identified by layered IP proxy patterns in network logs, indicating efforts to further obscure the true origin of transactions.
Multiple transactions initiated from IP addresses associated with public WiFi hotspots (e.g., coffee shops, airports, libraries) rather than typical residential or corporate networks.
Frequent switching between geographically disparate public WiFi locations within short time spans, inconsistent with a customer's normal travel or daily patterns.
Customer account registrations or modifications initiated from public WiFi networks accompanied by false or inconsistent personal identification details, raising doubts during the due diligence process.
High-value or rapid repeated fund transfers executed from unsecured public WiFi connections that deviate from the customer’s established transactional profile.
Discrepancies between the geolocation data of the transaction origin (public hotspot) and the customer’s registered or declared address during the CDD process.
Rapid changes in device fingerprints (e.g., browser signatures, device IDs) during sessions from public hotspots, reflecting potential deliberate obfuscation of the user’s identity.
Multiple session logs from distinct public WiFi networks accessing various customer accounts in a condensed timeframe, suggesting coordinated or systematic exploitation of public networks.
Multiple new customer accounts created from the same public WiFi hotspot in a short timeframe, indicating potential coordinated account openings.
Data Sources
- Provides IP logs, device usage patterns, and session metadata from online and mobile banking channels, revealing whether connections originate from public, potentially unsecured hotspots.
- Identifies VPN or proxy usage layered on public WiFi, helping detect deliberate obfuscation of user location and identity.
- Correlates multiple session logs to expose suspicious simultaneous or rapid-sequence logins from disparate public IP addresses, indicating potential coordinated misuse.
- Records timestamps, amounts, currencies, and IP addresses for all transactions, demonstrating when and where financial activities occur.
- Enables detection of unusual or rapid high-value transfers originating from public WiFi hotspots, highlighting deviations from typical account behaviors.
- Contains verified customer identities, documentation, and addresses, enabling the assessment of whether account openings or modifications align with legitimate user details.
- Facilitates the detection of suspicious or falsified identity information submitted from public WiFi locations, where criminals may mask their true details.
- Captures geolocation details for each transaction, allowing comparison of the actual transaction origin with the customer’s declared address or usual location.
- Highlights anomalies when transactions originate from diverse or distant public WiFi hotspots in short timeframes, indicating possible location obfuscation.
Mitigations
At onboarding, require enhanced identity verification for sign-ups initiated via public WiFi, including real-time document checks and secondary address confirmation. By demanding stronger proofs of identity from applicants connecting through open or anonymized networks, institutions can reduce fraudulent account openings that leverage untraceable IP addresses.
Implement targeted rules and analytics to detect transactions initiated from known public WiFi hotspots or from rapidly changing IP addresses consistent with hotspot hopping. Flag high-value or unusual transfers from these open networks for immediate review, verifying consistency with the customer’s typical location and transaction profile. This helps uncover attempts to obscure user identity and evade standard IP-based monitoring.
Require additional multi-factor authentication or step-up verification when sessions originate from recognized public WiFi IP addresses. Log and analyze repeated or concurrent logins from multiple hotspot locations—especially if combined with VPN or Tor usage—as strong indicators of malicious activity aiming to mask identity. By enforcing robust credential checks, institutions limit fraudulent access attempts via shared WiFi networks.
Train front-line and compliance personnel to recognize red flags associated with public WiFi usage, such as sudden shifts in location across distant hotspots, concurrent account logins from multiple public networks, or repeated use of anonymizing tools. Conduct scenario-based drills illustrating how criminals exploit public hotspots to obscure identity and how staff should escalate these findings.
Incorporate repeated public WiFi usage—and any associated VPN or Tor usage patterns—into automated risk scoring. Customers frequently accessing accounts from different hotspots or from IP addresses indicative of anonymizing tools are assigned a higher risk tier, triggering more intensive scrutiny, enhanced due diligence, or transaction limitations.
Impose conditional service limits or blocks on larger-value or high-risk transactions initiated from unverified public WiFi connections. For instance, require additional live identity verification or disallow certain transfers above a set threshold from open hotspots, thwarting criminals who rely on public networks to hide transaction origins.
Continuously validate the authenticity of customers who frequently initiate logins or transactions from public hotspots. Verify that declared addresses match geolocation data, and if discrepancies persist, prompt additional identity checks or impose tighter transaction controls. This measure ensures ongoing oversight of customers exploiting open WiFi anonymity over time.
Instruments
- Criminals open or access gambling platforms using transient public WiFi connections, bypassing geolocation checks that would typically flag improbable travel or repeated logins from suspicious addresses.
- Deposits, wagers, and withdrawals from these shared networks hinder the detection of linked accounts, making it difficult to identify the actual beneficial owners.
- Criminals connect to online banking portals from public WiFi hotspots, obscuring their true IP addresses and circumventing traditional device or location-based red flags.
- By rotating across multiple shared networks, they hinder efforts to reliably identify customers, complicating beneficial ownership tracing and transaction monitoring.
- By combining privacy-enhanced cryptocurrencies with the anonymity of public hotspots, criminals achieve layered obfuscation of both on-chain and network-level identifiers.
- Transactions originating from shared IP addresses offer little to no visibility into genuine user identities, complicating attribution for AML investigators.
- Criminals establish and log in to self-hosted wallets on unsecured hotspots, repeatedly switching networks to mask device and IP consistency.
- This practice defeats routine location-based analytics and complicates attempts to follow wallet ownership or usage patterns across multiple transactions.
- Offenders exploit open WiFi to register and fund prepaid accounts under different aliases or minimal KYC thresholds, evading consistent device fingerprinting.
- Rapid transfers among multiple prepaid balances created via shared hotspots impede banks' ability to detect linked patterns or correlate suspicious activity to a single user.
Service & Products
- Users connect to DeFi protocols from unsecured public hotspots, layering multiple transactions to blur on-chain provenance.
- Coupling public WiFi with anonymity tools like Tor further hampers KYC measures reliant on IP data or device fingerprints.
- Criminals coordinate trades from open WiFi hotspots to avoid linking activity to a fixed location or device.
- Rapid shifting of public networks complicates detection of repeat high-risk traders and hinders the identification of beneficial owners.
- Criminals exploit unsecured public WiFi to log in to mobile banking apps, bypassing device-based AML checks by frequently rotating devices or IP addresses.
- Use of shared hotspots conceals the user’s actual location, hampering geolocation-based risk detection.
- Public WiFi lets criminals create multiple accounts under different aliases with minimal overlap in device or IP data.
- Rapid transfers between shared-network users hamper the ability to trace ultimate beneficiaries of suspicious funds.
- Users establish or operate exchange accounts from public WiFi, undermining IP-based due diligence that would normally flag unusual login patterns.
- Deposits and withdrawals stem from shared IP addresses, concealing real user identity and complicating beneficial ownership tracing.
- Criminals log in from various public WiFi connections to trade securities anonymously, avoiding conventional IP-based AML triggers.
- Frequent sessions from shared hotspots frustrate pattern analysis, concealing suspicious trades and beneficial ownership ties.
- Illicit operators can set up or manage merchant accounts from public WiFi, masking user identities and complicating location-based transaction monitoring.
- Fraudulent payment requests or suspiciously large transactions are disguised as legitimate e-commerce flows, exploiting weak verification controls from open hotspots.
- Criminals access or top up digital wallets on open WiFi, defeating IP-based suspicious activity checks by using shared or transient addresses.
- They can move funds rapidly across multiple wallets while avoiding consistent device fingerprints, hindering AML efforts.
- Accessing digital accounts via public WiFi bypasses location-based risk parameters, blending illicit traffic with legitimate session logs.
- Multiple logins from diverse hotspots in short intervals defeat device recognition protocols, hindering AML investigations.
- Criminals exploit lax verification by accessing accounts over open WiFi, masking user identities behind shared IP addresses.
- Unusual transaction spikes from transient devices remain undetected due to high turnover of users on the same public network.
Actors
Illicit operators exploit public WiFi networks by:
- Initiating or facilitating illicit transactions under shared or transient IP addresses, obscuring their true location.
- Combining open hotspots with anonymity tools like VPNs or Tor, defeating IP-based risk scoring and device fingerprinting.
- Rapidly switching among multiple public connections, frustrating financial institutions’ efforts to reliably link suspicious activity to specific individuals or beneficial owners.
References
Financial Action Task Force of Latin America (GAFILAT). (2021). Guide on relevant aspects and appropriate steps for the investigation, identification, seizure, and confiscation of virtual assets. GAFILAT. https://biblioteca.gafilat.org/wp-content/uploads/2024/04/Guide-on-relevant-aspects-and-appropriate-steps-for-the-investigation-identification-seizure-and-confiscation-of-virtual-assets.pdf
AUSTRAC (Australian Transaction Reports and Analysis Centre). (2022, April). Preventing the criminal abuse of digital currencies. The Commonwealth of Australia. https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/preventing-criminal-abuse-digital-currencies