E-commerce & Marketplace Manipulation

Criminals fabricate or inflate online sales, payments, or refunds through websites and peer-to-peer marketplaces, layering illicit funds among seemingly legitimate commercial flows. They may create shell e-commerce sites, run sham purchases, or blend illegal proceeds with actual sales. In some variants, they use digital assets (e.g., NFTs, cryptocurrencies) for added anonymity or cross-border complexity. By making these transactions appear routine, criminals frustrate AML checks that rely on consistent billing, shipping, or payment records. They also exploit evolving e-commerce structures, including consumer-to-consumer or business-to-consumer marketplaces, where regulatory coverage may be limited. Fraudsters often set up counterfeit e-storefronts or replicate legitimate platforms to solicit payments and distribute counterfeit goods, and may rely on mobile-driven apps integrating social media and in-app payment channels. In some scams, items are never delivered, or refund mechanisms are manipulated to further obscure illicit proceeds, such as instances involving high-value products like treadmills sold online without actual shipment.

[
Code
T0028
]
[
Name
E-commerce & Marketplace Manipulation
]
[
Version
1.0
]
[
Parent Technique
]
[
Tactics
]
[
Risk
Channel Risk, Jurisdictional Risk
]
[
Created
2025-02-11
]
[
Modified
2025-04-02
]

E-Commerce Platforms for Layering

Tactics

ML.TA0007
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Criminals exploit e-commerce and marketplace manipulation by fabricating or inflating online sales, payments, or refunds to distribute illicit funds across numerous transactions and platforms, thereby breaking the direct link to their illicit origins. Blending illicit proceeds with legitimate sales flows explicitly obscures the true source of funds, constituting a core layering strategy.

Risks

RS0003
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Channel Risk
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Criminals exploit e-commerce platforms and peer-to-peer marketplaces, which are often lightly monitored or inconsistently regulated. By conducting non-face-to-face sales, refunds, and micro-transactions online, they obscure beneficial ownership and transactional flows, circumventing traditional AML checks that rely on in-person customer identification. This is the central vulnerability being exploited.

RS0004
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Jurisdictional Risk
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Criminals often operate across multiple jurisdictions with variable or weak AML oversight. By selecting cross-border e-commerce platforms, payment gateways, or crypto exchanges in regions with lax regulations, they exploit inconsistent standards to further conceal illicit proceeds.

Indicators

IND00452
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Goods or services consistently listed at significantly above-market prices without a legitimate business rationale.

IND00464
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High volumes of online transactions with limited or inconsistent shipping confirmations and no corresponding fulfillment records.

IND00476
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Multiple orders from newly created or unverifiable online accounts with inconsistent or contradictory customer details and no supporting identity documentation.

IND00483
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Multiple transactions from the same IP address or device ID under slightly varied customer details, lacking a legitimate explanation.

IND00488
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Payments through non-traditional channels (cryptocurrencies, offshore transfers, or prepaid instruments) that deviate from typical consumer usage or risk profiles.

IND00491
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Transactions combining small-value legitimate sales with larger, irregular amounts that remain below reporting thresholds, lacking a verifiable business or economic rationale.

IND00500
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Frequent or rapid changes to customer registration details, delivery addresses, or contact information without a clear business rationale, undermining consistent due diligence.

IND00501
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Duplicate or near-identical product listings across multiple seller profiles with no legitimate explanation, indicating coordinated fake orders or misrepresenting sales volume.

IND00502
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Frequent high-value refunds or return transactions with minimal justification or evidence of returned goods, especially in close temporal proximity to initial sales.

IND00503
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Recently established e-commerce storefronts exhibiting unusually large transaction volumes or revenue despite minimal online presence, reviews, or marketing.

Data Sources

Encompasses publicly available data from websites, social media, news outlets, and public records. This information helps identify duplicate product listings, verify inconsistent business claims, and detect newly established websites with suspiciously high transaction volumes or minimal online presence, revealing potential fraudulent e-storefronts.

Provides comprehensive records of monetary transactions, including timestamps, amounts, currencies, counterparties, and transaction types. This data helps detect unusual payment methods, structuring below reporting thresholds, and large or irregular flows tied to fraudulent online storefronts, enabling analysts to uncover potential layering of illicit proceeds.

Collects transaction details, user identifiers, shipping confirmations, and refund records from e-commerce and digital payment services. This data allows analysts to identify inflated pricing, detect unfulfilled orders, spot frequent high-value refunds with minimal justification, and pinpoint other suspicious patterns indicative of manipulated online sales or sham transactions.

Captures user login activities, IP addresses, device IDs, and related metadata for e-commerce or payment apps. This data helps identify suspicious usage patterns, such as multiple transactions from the same IP or device under different accounts, revealing potentially coordinated manipulation.

Contains verified identities, beneficial ownership, addresses, and account relationships. This data is crucial for detecting newly created or unverifiable online accounts, frequent or rapid changes in customer details, and mismatched identity information, all of which indicate potential fraudulent e-commerce activities.

Provides on-chain transaction data, including transaction IDs, wallet addresses, timestamps, and transferred values. This data enables the detection of cross-border digital asset flows, identification of suspicious or high-risk crypto usage within e-commerce transactions, and tracing of NFTs or other tokens potentially used to layer illicit funds.

Provides official and aggregated corporate registration details, including beneficial ownership data, directors, and historical ownership changes. This facilitates the verification of e-commerce businesses, detection of shell or front companies, and exposure of hidden ownership structures used to launder funds through fraudulent online storefronts.

Mitigations

Subject merchants with unusually large refund volumes, unexplained shipping anomalies, or contradictory domain and registration data to deeper scrutiny. Verify beneficial ownership, supply chain partners, and source of funds to expose layered illicit proceeds.

Require newly formed or high-volume e-commerce merchants to provide verifiable business documentation, domain registration details, and shipping or fulfillment records. Confirm that products offered match actual inventory and correlate with the merchant’s stated line of business to prevent sham storefronts and inflated sales.

Implement rules-based or advanced analytics tailored to e-commerce flows, flagging suspicious patterns such as recurring large refunds, multiple orders from a single IP with slight variations in buyer credentials, or goods consistently priced well above market norms.

Analyze on-chain data for NFT or cryptocurrency payments linked to e-commerce transactions by tracing fund flows, identifying unusual wallet cluster activity, and correlating off-chain sales data with on-chain movements.

Provide targeted training on the hallmarks of e-commerce fraud, such as repeated large refunds without legitimate return processes, contradictory shipping data, or rapid spikes in marketplace sales by newly established sellers.

Use escrow accounts for high-value online sales, withholding funds until buyers confirm receipt and delivery records match shipping carriers' data. Release payments only once order fulfillment is validated.

Check the merchant’s online presence, domain age, reviews, and advertised product information against independent sources to confirm the legitimacy of e-commerce storefronts and product offerings.

Cross-verify e-commerce shipping documents, tracking numbers, and fulfillment records with independent logistics data. Identify repeated non-delivery of goods, inflated invoice values, or mismatched shipping volumes that signify manipulated transactions.

Instruments

  • Perpetrators list intangible digital items (e.g., downloadable software, in-game assets) at inflated prices, then repeatedly 'purchase' these goods with illicit funds.
  • The nominally legitimate commerce structure makes it challenging to distinguish criminal money flows from ordinary customer transactions, thus adding a layer of complexity to AML efforts.
  • Criminals establish merchant or business bank accounts linked to their e-commerce storefronts to receive proceeds from sham sales, inflated refunds, or fabricated orders.
  • By mixing illicit earnings with legitimate online transactions, they create a layered flow that appears to be standard commercial income, making it harder to detect the criminal source of funds.
  • Criminals mint or list NFTs on e-commerce-like marketplaces, artificially inflating prices by buying from themselves.
  • Pseudonymous accounts and the ease of cross-border digital transfers provide additional anonymity benefits, allowing illicit funds to be laundered under the guise of art or collectible sales.
  • Offenders integrate cryptocurrency payment options into e-commerce storefronts or peer-to-peer marketplaces, enabling cross-border transactions that are more difficult to track.
  • They convert illicit funds into or out of cryptocurrency through fabricated sales and refunds, leveraging decentralized networks and pseudonymous wallets to mask their illicit origins.
  • Fraudsters route illicit funds through bogus online sales by charging their own or stolen payment cards, generating artificial revenue.
  • They also manipulate refund processes, crediting illicit proceeds back onto cards in ways that appear consistent with routine customer returns, obscuring the true source of the funds.
  • Criminals purchase prepaid cards or load e-wallets with illicit funds and then simulate legitimate purchases on their own storefronts.
  • The resulting transactions appear as bona fide retail activity, while the stored-value instruments’ potentially weaker KYC channels and easy reload features help layer and obscure the original dirty funds.

Service & Products

  • Criminals combine sham e-commerce listings with direct crypto-for-fiat trades, leveraging pseudonymous handles to further obscure beneficial ownership.
  • Limited or no central oversight in peer-to-peer transactions complicates regulatory monitoring, facilitating cross-border layering of illicit proceeds.
  • Criminals establish fake or replica storefronts, listing counterfeit or non-existent goods to process sham purchases.
  • Fraudulent orders and manipulated refunds enable layering of illicit proceeds, masking them as legitimate commercial transactions and complicating AML checks.
  • Criminals rely on consumer-to-consumer payment apps to fabricate private sales and shipping records, creating the appearance of legitimate e-commerce activity.
  • Minimal KYC or identity checks on peer-to-peer networks help mask the source or destination of illicit funds, hindering AML efforts.
  • Criminals funnel suspicious or inflated e-commerce payments through mainstream processors, intermingling illicit funds with legitimate flows.
  • Automated approvals and rapid settlement processes can limit effective oversight, enabling criminals to obscure transaction details and bypass routine AML triggers.
  • By integrating mobile and web-based payment channels, criminals execute numerous micro-transactions or refunds, complicating any transactional review.
  • Frictionless payment setups allow the quick injection or extraction of illicit funds, circumventing traditional banking scrutiny.

Actors

AT0007
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Criminals use their own or stolen cardholder details to perform bogus online purchases. Refunds then appear as legitimate reversals of customer transactions, ultimately redistributing illicit proceeds back onto cards or accounts. This practice masks the source of funds and complicates financial institutions' transaction monitoring.

Cybercriminals knowingly orchestrate e-commerce manipulation schemes by:

  • Creating counterfeit storefronts or hijacking legitimate platforms, making them appear as genuine online commerce.
  • Managing sham listings and artificially inflating sales and refunds.

These activities exploit digital anonymity, complicating financial institutions' monitoring and detection efforts.

Online marketplaces, including peer-to-peer platform operators, are exploited by criminals to:

  • Post sham or counterfeit goods and services, driving phony revenues.
  • Conduct consumer-to-consumer or business-to-consumer sales with minimal KYC or transaction scrutiny.

These factors hinder financial institutions' ability to trace beneficial ownership or verify transaction authenticity.

Criminals form shell or front companies to establish fraudulent e-commerce businesses with minimal real operations. By mixing illicit proceeds with nominal legitimate income, they create transactions that appear routine, hindering financial institutions' ability to detect suspicious flows.

Payment service providers may unwittingly process criminal transactions by:

  • Rapidly approving or settling e-commerce payments and refunds with limited oversight.
  • Handling an array of small or micro-transactions that collectively launder significant illicit funds.

Insufficient verification of merchant legitimacy and transactional patterns reduces the effectiveness of AML controls.

Peer-to-peer exchange operators facilitate direct crypto-for-fiat or crypto-for-crypto transactions. Criminals exploit this by combining fake e-commerce listings with P2P trades to:

  • Inject illicit funds into cryptocurrency markets, bypassing traditional controls.
  • Exploit pseudonymous user identities and decentralized exchanges, hindering AML oversight by financial institutions.
AT0085
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A merchant role, whether legitimate or criminally controlled, processes online orders and payments. Criminals posing as merchants:

  • Generate artificial sales revenue from illicit funds.
  • Manipulate refund mechanisms to reroute criminal proceeds onto cards or accounts.

These tactics obscure the fraudulent origin of funds, challenging financial institutions' risk assessments and transaction monitoring.

References

  1. APG (Asia/Pacific Group on Money Laundering). (2021, July). APG Yearly Typologies Report 2021. Asia/Pacific Group on Money Laundering. https://apgml.org/documents/default.aspx

  2. Europol. (2023). The other side of the coin: An analysis of financial and economic crime. Publications Office of the European Union. https://www.europol.europa.eu/publications-events/publications/other-side-of-coin-analysis-of-financial-and-economic-crime

  3. FATF (Financial Action Task Force), Interpol, Egmont Group. (2023, November). Illicit financial flows from cyber-enabled fraud. FATF. http://www.fatf-gafi.org/content/fatf-gafi/en/publications/Methodsandtrends/illicit-financial-flows-cyber-enabled-fraud.html

  4. Akartuna, E. A., Johnson, S.D.,Thornton, A.E. (2022, September). The money laundering and terrorist financing risks of new and disruptive technologies: a futures-oriented scoping review. Springer Nature. https://link.springer.com/article/10.1057/s41284-022-00356-z

  5. Babuta, A., Haenlein, C., Reid, A. (2018). E-Commerce, delivery services and the illicit tobacco trade. Royal United Services Institute for Defence and Security Studies. https://www.rusi.org/explore-our-research/publications/occasional-papers/e-commerce-delivery-services-and-illicit-tobacco-trade