Offshore or Secrecy Exploitation

Criminals deliberately conduct business in regions with weak regulatory oversight or secrecy laws, exploiting minimal compliance standards, tax advantages, and protective legislation. Such high-risk jurisdictions offer reduced customer due diligence, bank secrecy, and limited beneficial ownership disclosures, facilitating anonymity and impeding effective oversight. Adversaries commonly initiate or route illicit funds through local financial institutions, layering the proceeds via multiple accounts or corporate structures. They often make numerous international transfers to foreign accounts in tax havens, sometimes held under the same name to further obfuscate origins and conceal ultimate ownership. In certain cases, perpetrators also leverage stored value products or prepaid cards that are deposited or redeemed in high-risk jurisdictions to exploit additional regulatory gaps. These practices deter detection, hinder sanctions enforcement, and complicate cross-border investigations, as law enforcement often encounters limited cooperation and opaque financial channels that obscure the illicit flow of funds.

[
Code
T0062
]
[
Name
Offshore or Secrecy Exploitation
]
[
Version
1.0
]
[
Parent Technique
]
[
Risk
Jurisdictional Risk
]
[
Created
2025-02-13
]
[
Modified
2025-04-02
]

Exchange in Non-Cooperative Jurisdiction

Exploitation of High-Risk Jurisdictions

Tactics

Offshore secrecy laws, limited beneficial ownership disclosure, and protective legislation specifically obscure true ownership and the criminal origin of funds, forming a vital concealment layer.

By exploiting minimal AML oversight and weak KYC requirements in certain jurisdictions, criminals find entry points into the global financial system, thereby circumventing stricter controls in more regulated markets.

ML.TA0007
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Criminals exploit secrecy-friendly jurisdictions by executing multiple cross-border transfers and layered corporate structures, explicitly distancing illicit proceeds from their source to thwart straightforward detection of their origin.

Risks

RS0004
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Jurisdictional Risk
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Criminals deliberately exploit secrecy-friendly or weakly regulated jurisdictions, leveraging minimal customer due diligence, reduced beneficial ownership disclosures, and lax oversight to layer illicit funds. By routing transactions through these high-risk regions, they impede cross-border cooperation, obscure account origins, and take advantage of strong bank secrecy or limited compliance requirements. This is the primary vulnerability enabling anonymity and thwarting investigative efforts.

Indicators

IND00103
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Frequent or high-value transactions initiated or routed through financial institutions or exchange services in jurisdictions with weak regulatory oversight, lacking a clear commercial rationale.

IND00107
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Frequent currency conversions or exchanges using platforms based in high-risk jurisdictions, especially when such activity deviates from the customer’s known business profile.

IND00144
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Customer records or account profiles showing addresses or registered entities in high-risk jurisdictions that are inconsistent with declared domicile or business operations.

IND00145
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Lack or minimal documentation provided during account opening or due diligence processes for services in high-risk jurisdictions.

IND00146
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Reluctance or evasiveness when asked to provide a rationale for using exchange services in high-risk jurisdictions or to clarify the origin and destination of funds.

IND00150
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Frequent loading or redemption of prepaid cards or stored value products in high-risk jurisdictions, inconsistent with typical usage patterns.

IND00197
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Multiple corporate or personal accounts in different high-risk jurisdictions under the same beneficial owner, lacking a coherent commercial or personal rationale.

Data Sources

  • Maps countries, territories, and regions to their AML/CFT risk profiles, highlighting secrecy jurisdictions or areas with weak oversight.
  • Facilitates enhanced screening of transactions and accounts linked to high-risk locations.
  • Supports risk-based monitoring and alerts when repeated or unexplained usage of such jurisdictions is detected.

Provides comprehensive records of currency conversion activities, including spot trades, forward contracts, and swaps. It captures timestamps, exchange rates, volumes, counterparties, and settlement details to identify repeated or high-volume conversions in high-risk jurisdictions. This enables the detection of suspicious foreign exchange patterns and anomalies that deviate from established customer profiles.

  • Logs prepaid card loading, usage, and redemption events, including geographical points of transaction.
  • Flags frequent or high-value card activities in secrecy jurisdictions that deviate from typical customer profiles.
  • Reveals hidden layering or structuring attempts using stored value products in offshore locations.
  • Captures detailed transaction records, including timestamps, amounts, currencies, sender/receiver details, and reference IDs, for both domestic and cross-border payments.
  • Enables detection of repeated or structured flows to and from secrecy jurisdictions, revealing potential layering and unusual routing of funds.
  • Facilitates pattern analysis to spot anomalies or deviations from a customer’s typical profile, highlighting offshore exploitation risks.
  • Stores submitted KYC documents, corporate filings, and other due diligence records.
  • Detects incomplete or insufficient supporting information for accounts linked to high-risk jurisdictions.
  • Enables auditors to trace submission timelines and identify purposeful document gaps that hinder transparency.
  • Includes verified identities, addresses, beneficial ownership data, and customer risk metrics.
  • Highlights discrepancies or incomplete information related to high-risk jurisdictions.
  • Assists investigators in assessing whether offshore entities or addresses align with declared business operations, revealing potential secrecy exploitation.
  • Captures logs of customer interactions (emails, calls, messages) where permissible by law.
  • Documents reluctance or evasiveness in justifying fund origins or offshore transactions.
  • Helps investigators correlate suspicious communication patterns with cross-border or secrecy jurisdiction activity.
  • Consolidates cross-border payment flows, including involved financial institutions, jurisdictions, currencies, and settlement information.
  • Pinpoints high-risk or secrecy jurisdictions in transaction chains, helping to track layered or repeated transfers designed to obscure beneficial ownership.
  • Supports the investigation of offshore or secrecy exploitation by maintaining a clear record of international money movements and counterparty relationships.
  • Provides official incorporation details, shareholder structures, and historical ownership changes for legal entities.
  • Verifies whether multiple companies are registered in high-risk or secrecy jurisdictions under the same beneficial owner.
  • Uncovers cross-jurisdictional layering and hidden ownership links facilitating offshore exploitation.

Mitigations

Institute a systematic country risk assessment that classifies jurisdictions based on factors such as regulatory strength, secrecy laws, and known levels of financial crime. Assign higher risk ratings to customers, counterparties, and transactions involving these locations. This should trigger enhanced monitoring, additional due diligence, or service restrictions to counter potential abuse of weak oversight regimes.

Perform thorough Enhanced Due Diligence (EDD) on customers or exchanges based in, or routing transactions through, high-risk jurisdictions. Verify licensing status, review the robustness of KYC/AML controls, request ownership and control documentation, and consult beneficial ownership registries to uncover undisclosed controlling parties. Require enhanced due diligence questionnaires and supporting evidence to confirm legitimate operations, helping to minimize exposure to entities exploiting weak regulatory frameworks.

Routinely screen the names, beneficial owners, and key stakeholders of entities operating in or transacting through high-risk jurisdictions against relevant sanctions lists, PEP databases, and adverse media. Immediately flag or restrict relationships involving sanctioned or suspicious parties to prevent the abuse of secrecy laws and weak oversight found in certain regions.

Use advanced blockchain analytics to detect addresses and transactions linked to high-risk or sanctioned jurisdictions, tracing the flow of digital assets across borders. Identify layering attempts involving multiple accounts or unregulated exchanges domiciled in secrecy-friendly locales. Investigate unusual volume or velocity of funds moving to or from these jurisdictions to expose efforts to obscure illicit proceeds.

Instruments

  • In high-risk jurisdictions, banks often have weaker customer due diligence standards, allowing criminals to open or maintain accounts with minimal scrutiny.
  • Funds can be quickly transferred between multiple accounts in secrecy-friendly locations, making it harder for authorities to trace the true origin or beneficial owner.
  • Bank secrecy laws and limited disclosure requirements in these regions hide the identity of illicit operators, inhibiting cross-border investigation and enforcement efforts.
  • Jurisdictions with lax corporate transparency allow the issuance of bearer shares, which require no registered owner.
  • Criminals transfer ownership by merely handing over the physical certificates, sidestepping any beneficial ownership records.
  • This arrangement hides the true controllers of funds, preventing financial institutions and regulators from identifying the parties behind cross-border transactions.
  • Criminals load or withdraw value on prepaid cards in jurisdictions with lax KYC checks, limiting paper trails.
  • Redeeming these cards across borders obscures the link to illicit proceeds, as minimal information is collected in secrecy-oriented regions.
  • This method exploits regulatory gaps, bypassing standard transaction monitoring and impeding cross-border cooperation.

Service & Products

  • Acquire or load prepaid cards in high-risk jurisdictions where weak KYC requirements enable anonymous or minimally verified fund deposits.
  • Redeem or withdraw these cards across different countries, masking the origin of illicit proceeds and exploiting regulatory gaps.
  • Provide bank accounts in jurisdictions with strong secrecy laws and minimal regulatory oversight, enabling anonymity for illicit fund storage.
  • Facilitate large-scale transfers to or from high-risk locations while limiting beneficial ownership disclosure and customer due diligence requirements.
  • Facilitate rapid international transfers to accounts in tax havens, assisting in layering and concealing beneficial ownership.
  • Leverage weak AML measures and limited data-sharing across borders, rendering it more difficult to trace funds effectively.
  • Allow the formation of corporations in secrecy jurisdictions with reduced corporate transparency and limited beneficial ownership disclosure.
  • Enable multiple shell or front companies to hold and move funds across borders under obscured ownership structures, complicating investigations.

Actors

Prepaid card issuers operating within or servicing high-risk jurisdictions may inadvertently enable illicit actors to load and redeem funds with minimal verification. This setup conceals the origin of proceeds and complicates transaction monitoring for financial institutions investigating cross-border card usage.

Offshore financial institutions located in high-risk or secrecy jurisdictions may knowingly or unwittingly provide accounts with minimal transparency. Their limited customer due diligence and strong banking secrecy enable illicit operators to layer funds, hindering other financial institutions' ability to trace transactions across borders.

Illicit operators deliberately use high-risk jurisdictions with weak AML oversight to deposit and layer funds through local accounts and corporate structures. By exploiting minimal due diligence requirements, they obscure beneficial ownership, impeding financial institutions' monitoring and cross-border investigative efforts.

Offshore entities established in high-risk jurisdictions provide limited disclosure of beneficial ownership, enabling illicit operators to hold or move funds under opaque structures. These arrangements complicate financial institutions' ability to identify true owners, facilitating layering and cross-border transactions.

References

  1. AUSTRAC (Australian Transaction Reports and Analysis Centre). (2022). Money laundering and terrorism financing risk assessment: Remittance network providers and affiliates. AUSTRAC. https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/remittance-network-providers-and-their-affiliates-australia-risk-assessment-2022

  2. AUSTRAC (Australian Transaction Reports and Analysis Centre). (2019). Australia's mutual banking sector money laundering and terrorism financing risk assessment. Commonwealth of Australia. https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/risk-assessment-mutual-banking-sector

  3. AUSTRAC (Australian Transaction Reports and Analysis Centre). (2017). Non-profit organisations & terrorism financing regional risk assessment 2017. Commonwealth of Australia. https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/non-profit-organisations-and-terrorism-financing-regional-risk-assessment-2017

  4. AUSTRAC (Australian Transaction Reports and Analysis Centre). (2017, April). Money laundering and terrorism financing risk assessment. AUSTRAC. http://www.austrac.gov.au

  5. Heikkilä, I. (2023). Money Laundering and Terrorist Financing Indicators. National Bureau of Investigation, Financial Intelligence Unit (FIU). http://www.rahanpesu.fi