Criminals acquire prepaid cards and e-wallets (also known as digital or mobile wallets) issued by financial institutions in offshore or secrecy jurisdictions, sometimes presenting fake or unverified documents to bypass issuer safeguards. These products often feature minimal KYC requirements and allow illicit funds to be deposited repeatedly in small increments to evade analytical thresholds. Using forged papers or misleading ID further impairs effective due diligence, enabling multiple top-ups from unknown sources. Because these offshore instruments can facilitate cross-border transfers or withdrawals with partial anonymity and limited monitoring, launderers integrate the funds into larger financial channels, frequently layering them among multiple accounts. Some criminals also link these e-wallets to online gambling or related services, shuffling capital across different platforms to obscure its origin. The focus here is on pseudo-individual or personal accounts from offshore issuers, where weak identity checks encourage repeat loading and near-anonymous use. This approach relies on stored-value products in secrecy havens to conduct rapid layering, micro-transactions, and dispersed payouts, posing serious challenges to AML/CFT measures.
Offshore Prepaid and E-Wallet Issuance
Tactics
Criminals deliberately exploit minimal KYC or use forged IDs to open offshore e-wallet or prepaid card accounts, circumventing AML controls and establishing a discreet entry point into the financial system. This is a core objective because it enables them to bypass standard customer due diligence requirements from the outset.
Once obtained, these offshore prepaid or e-wallet accounts are repeatedly topped up below reporting thresholds and used in cross-border transactions, blending illicit funds with legitimate flows. This practice obscures origins and creates multiple transactional layers.
Risks
This technique primarily exploits the inherent vulnerabilities of stored-value instruments, such as prepaid cards and e-wallets, by leveraging low or minimal KYC requirements, partial anonymity, and easy cross-border usage. These features enable repeated reloading and near-anonymous transactions to layer illicit funds. The product features are the central operational weakness facilitating the laundering scheme.
Criminals deliberately source these instruments from secrecy or offshore jurisdictions with weak AML oversight, reinforcing anonymity and making cross-border detection more difficult.
Indicators
Frequent micro-deposits into an offshore e-wallet or prepaid card from multiple, unrelated external accounts with minimal intervals between transactions.
Repeated cross-border transfers from secrecy jurisdictions into offshore-issued e-wallets or prepaid cards, followed by rapid consolidation or withdrawals.
Account holders provide incomplete or forged identity documents to open or maintain offshore e-wallet or prepaid card accounts, circumventing standard KYC requirements.
Multiple e-wallet or prepaid card accounts under the same individual or interconnected parties receiving frequent top-ups from unrelated sources.
Offshore e-wallet or prepaid card is repeatedly funded and used on online gambling platforms with minimal gameplay, followed by withdrawals or transfers.
Sequential transfers of funds from an offshore e-wallet across multiple intermediate accounts or payment platforms, obscuring the original funding source.
Offshore prepaid card or e-wallet issuer is registered in a known secrecy haven or high-risk jurisdiction with lenient AML controls.
Data Sources
Consolidates risk profiles of countries and territories, including secrecy or high-risk jurisdictions. This data helps identify offshore or uncooperative issuers of prepaid cards and e-wallets, enabling targeted monitoring of cross-border activities likely to facilitate laundering.
Offers detailed records on prepaid card usage, including individual card identifiers, deposit and withdrawal timestamps, transaction amounts, and usage frequencies. Investigators can identify repeated or high-volume reloads, small-amount structuring, and offshore usage patterns tied to secrecy-jurisdiction prepaid cards.
Provide a comprehensive record of all financial transactions, including timestamps, transaction identifiers, amounts, and cross-border details. Tracking deposit frequencies, reload behaviors, and offshore flows helps uncover structuring, micro-deposits, and suspicious layering in prepaid and e-wallet accounts issued by secrecy-jurisdiction providers.
Includes e-wallet transaction information, user account details, balances, and usage patterns. Analysis of cross-border transfers, partial anonymity features, and repeated low-value transactions helps detect layering and threshold evasion linked to offshore e-wallet issuers.
Provides authentication results for submitted identification documents, highlighting any forgeries or inconsistencies. Detecting falsified IDs is essential when criminals exploit minimal verification protocols offered by offshore prepaid and e-wallet providers.
Contains verified identities, customer backgrounds, beneficial ownership data, and due diligence risk findings. Reviewing these details enables financial institutions to detect forged or unverified documentation and identify suspicious account holders acquiring offshore prepaid cards or e-wallets.
Captures cross-border transaction details, covering participating financial institutions, currencies, and settlement processes. Analyzing these records reveals foreign reloads, withdrawals, and transfers linked to offshore e-wallets or prepaid cards, highlighting potential layering through secrecy jurisdictions.
Mitigations
Regularly evaluate and categorize issuing jurisdictions based on AML controls, regulatory oversight, and known secrecy practices. Flag high-risk offshore territories for more stringent checks, such as requiring proof of local regulatory compliance or additional verification steps for e-wallet or prepaid card issuers operating from these regions.
Apply deeper scrutiny for customers holding offshore-issued prepaid or e-wallet products, including detailed source-of-funds checks and verification of any declared identities or addresses in secrecy jurisdictions. Conduct closer scrutiny of ongoing transaction patterns. Require senior management approval before allowing high-risk customers to reload balances, ensuring elevated controls for these accounts.
Require robust, upfront identity verification steps for prepaid card or digital wallet applicants, particularly when products originate from offshore issuers. For example, mandate validation of provided identification through official government databases or credible external sources, and reject accounts that do not conclusively verify legal identity. This prevents criminals from leveraging low-tier or forged documentation commonly used to open these offshore accounts.
Implement rules-based and analytics-driven monitoring specifically designed to detect repeated micro-loads below reportable thresholds, cross-border transfers to or from known secrecy jurisdictions, and sudden spikes in e-wallet or prepaid card balances. Investigate flagged accounts promptly to disrupt layering via incremental top-ups.
If partnering with offshore prepaid card or e-wallet issuers, require formal audits of their AML policies and ID verification procedures. Enforce ongoing oversight in service-level agreements, ensuring that external issuance programs meet the same KYC and anti-forgery standards as the institution’s in-house protocols.
Classify prepaid or e-wallet customers tied to offshore or secrecy jurisdictions into higher-risk tiers, assigning more stringent oversight and tailored transaction limits. Use data points such as issuing authority, loading frequency, and cross-border destination to differentiate normal users from potential laundering networks.
Cross-check the purported identity and background of customers presenting foreign government IDs or non-traditional documents with open-source data, such as public records, governmental websites, or news outlets. Confirm the legitimacy of offshore addresses and personal details to detect fabricated or opportunistically provided false information.
Restrict or prohibit certain account features, such as unlimited international withdrawals or reloads, for prepaid or e-wallet accounts linked to high-risk offshore issuers. For example, impose lower transaction limits or require additional approvals for cross-border usage to prevent the unchecked reloading of illicit funds.
Continuously re-verify offshore-issued prepaid or e-wallet accounts by assessing transaction histories, geographic patterns, and any changes in the customer profile. For instance, prompt a review if an account consistently loads funds from unfamiliar or unverified sources, ensuring sustained scrutiny after the initial onboarding.
Instruments
- Offshore prepaid or e-wallet balances are linked to online gambling platforms, where criminals deposit funds to obscure their source.
- Minimal gameplay or multiple bets create transactional layers, with winnings or withdrawals then moved into different accounts.
- This linkage leverages partial anonymity and weak verification in some online gambling sites to further conceal and shuffle illicit funds.
- Criminals acquire offshore-issued prepaid cards and e-wallets where weak or minimal KYC controls allow them to register under forged or unverified identities.
- They repeatedly load small amounts of illicit funds onto these instruments, staying under reporting thresholds to avoid triggering AML suspicion.
- Once loaded, these prepaid or e-wallet accounts can be used for cross-border transactions or cash withdrawals with limited oversight, effectively layering and dispersing illicit proceeds.
Service & Products
- Criminals obtain offshore-issued prepaid cards under minimal or falsified identification, exploiting weak KYC controls.
- They repeatedly load illicit funds in small amounts to evade reporting thresholds, enabling layering through seemingly innocuous transactions.
- The cards can be used internationally, blending illicit transfers with legitimate expenditures and complicating AML monitoring.
- Criminals open offshore e-wallet accounts with forged or low-verification documentation, bypassing stronger onshore due diligence.
- Ongoing micro-deposits disguise the origin of funds, leveraging partial anonymity to obscure the money trail.
- These wallets facilitate rapid cross-border transfers and withdrawals, creating multiple transaction layers that frustrate detection.
- Offshore e-money issuers often have minimal compliance regimes, allowing criminals to register accounts without robust identity checks.
- Repeated, low-value top-ups help obscure illicit origins and circumvent transaction monitoring.
- Funds can then be transferred, spent, or withdrawn cross-border with limited scrutiny, facilitating layering and eventual integration.
Actors
Offshore financial institutions issuing or managing stored-value instruments are exploited when:
- They provide prepaid cards, e-wallets, or similar products with minimal or weak KYC.
- Criminals use forged or easily accepted identification to open and top up accounts repeatedly below reporting thresholds.
- Cross-border withdrawals or payments occur under limited oversight, enabling funds to be layered into global financial channels.
These gaps challenge other financial institutions’ ability to trace transaction sources or identify beneficial owners, amplifying money laundering risks.
Illicit operators acquire offshore prepaid and e-wallet accounts by:
- Using false or unverified identification to bypass issuer KYC checks.
- Repeatedly reloading funds under threshold limits, layering illicit proceeds.
- Moving funds across borders via near-anonymous transactions, obscuring their origins.
These behaviors complicate risk assessments for financial institutions, as the underlying source of funds and true identities remain concealed.
Document forgers support illicit operators by:
- Producing or altering identification documents that circumvent or defeat the issuer’s verification controls.
- Enabling criminals to maintain multiple accounts or identities, undermining standard KYC measures.
By facilitating the creation of forged credentials, these actors increase the risk that financial institutions will onboard accounts without detecting the true beneficial owners.
References
APG (Asia/Pacific Group on Money Laundering). (2020, September). APG Yearly Typologies Report 2020. APG Secretariat. https://apgml.org/documents/default.aspx
MENAFATF (Middle East and North Africa Financial Action Task Force). (2023). MENAFATF Biennial Typologies Report - 2022. MENAFATF. https://www.menafatf.org/sites/default/files/Newsletter/MENAFATF%20BIENNIAL%20TYPOLOGIES%20REPORT.pdf
MONEYVAL. (2013, April). The use of online gambling for money laundering and the financing of terrorism purposes. https://rm.coe.int/research-report-the-use-of-online-gambling-for-money-laundering-and-th/168071509c
AUSTRAC (Australian Transaction Reports and Analysis Centre). (2017, April). Money laundering and terrorism financing risk assessment. AUSTRAC. http://www.austrac.gov.au