Transaction Chaining

Transaction Chaining involves executing a series of transactions, often rapidly or consecutively, across multiple jurisdictions and through various accounts to obscure the origin and trail of illicit funds. This method commonly leverages cryptocurrencies or other easily transferable digital assets, including cross-asset “chain hopping” via blockchain bridges, which complicates traceability and evades traditional analytics solutions. Criminals also split large sums into many smaller or micro-transactions (“peel chains”), ensuring that most alerts and reporting thresholds are not triggered. In some cases, they exploit off-chain or Layer 2 scaling solutions—such as the Lightning Network—to settle transactions more quickly and reduce on-chain visibility, creating additional barriers to investigation. By dispersing transactions among different platforms and locations, this technique produces multiple layers of complexity, frustrating investigators’ attempts to follow the funds and identify ultimate beneficiaries.

[
Code
T0070
]
[
Name
Transaction Chaining
]
[
Version
1.0
]
[
Parent Technique
]
[
Tactics
]
[
Risk
Channel Risk, Jurisdictional Risk
]
[
Created
2025-02-24
]
[
Modified
2025-04-02
]

Tactics

ML.TA0007
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Transaction chaining involves repeated transfers across multiple accounts, platforms, or blockchains. It uses rapid cross-asset "chain hopping" and micro-transactions to systematically distance illicit funds from their origin. This complexity explicitly frustrates efforts to trace the money trail.

Risks

RS0003
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Channel Risk
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Criminals exploit digital and cross-border transaction channels that permit rapid, successive transfers, including chain-hopping, micro-transactions, and off-chain or Layer 2 solutions, with limited face-to-face scrutiny. The complex nature of these delivery methods, coupled with minimal direct oversight, is the primary vulnerability leveraged in transaction chaining to obscure the origin and trail of illicit funds.

RS0004
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Jurisdictional Risk
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By rapidly moving funds among different countries and regulatory environments, criminals exploit inconsistencies in AML enforcement across multiple jurisdictions. This cross-border complexity frustrates investigators' ability to follow the transaction trail and ensure consistent compliance checks.

Indicators

IND00741
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Complex transaction structures with multiple layers of transfers that lack economic justification.

IND00877
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Frequent cross-border transactions involving multiple jurisdictions within a short time frame.

IND00878
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Use of multiple intermediary accounts across different countries in a single transaction chain.

IND00879
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Rapid movement of funds between accounts in various countries without a clear business purpose.

IND01856
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Frequent opening and closing of accounts in different jurisdictions by the same customer.

IND02057
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Involvement of jurisdictions known for weak AML regulations or secrecy laws in transaction chains.

IND02058
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Transactions involving jurisdictions with no apparent business relationship or customer presence.

IND02059
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Sudden changes in transaction patterns, such as increased international activity, without clear rationale.

IND02060
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Frequent cross-asset bridging or 'chain hopping' of digital assets across multiple blockchain networks within short intervals.

IND02061
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Use of off-chain or Layer 2 solutions (e.g., Lightning Network) to facilitate high-volume micro-transactions that are not visible on main blockchain ledgers.

IND02062
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Splitting large sums into multiple small ‘peel chain’ transactions across several digital wallets to avoid detection thresholds.

Data Sources

  • Consolidates risk profiles of various jurisdictions, including known secrecy havens.
  • Highlights high-risk regions with weak AML regulations frequently involved in transaction chaining.
  • Helps investigators detect transfers passing through or originating in jurisdictions with no legitimate connection to the customer.
  • Captures timestamps, amounts, currencies, parties, and transaction identifiers across multiple channels.
  • Facilitates detection of micro-transactions, rapid fund flows, and layering across accounts or institutions.
  • Enables investigators to reconstruct complex transaction patterns and trace funds through multiple layers involved in transaction chaining.
  • Provides user account information, transaction logs, and bridging activities across digital asset platforms.
  • Helps link multiple wallets or accounts under the same user engaging in cross-asset transfers.
  • Supports detection of unusual transaction volumes and rapid bridging frequently involved in transaction chaining.
  • Contains verified customer identities, beneficial ownership details, and account relationships.
  • Enables linking of multiple accounts or entities controlled by the same individual, which is vital in identifying rapid account openings or closures used in Transaction Chaining.
  • Assists in revealing suspicious patterns where a single customer repeatedly opens accounts in different jurisdictions without clear business rationale.
  • Tracks on-chain digital asset transactions, including wallet addresses, timestamps, and transaction amounts.
  • Enables detection of cross-asset 'chain hopping' and peel chain patterns used to split large sums into micro-transactions.
  • Assists investigators in tracing funds that move rapidly across multiple blockchain networks, common in transaction chaining.
  • Provides details on cross-border transactions, including amounts, involved countries, and intermediary institutions.
  • Enables detection of frequent or high-risk cross-jurisdictional transfers, a hallmark of Transaction Chaining.
  • Assists investigators in identifying unusual multi-jurisdictional transaction routes that lack economic justification.

Mitigations

Apply deeper scrutiny to customers or accounts exhibiting high-velocity or multi-jurisdiction transaction patterns, particularly when funds move rapidly in or out without a credible business explanation. Verify sources of wealth and validate the legitimacy of frequent cross-border flows. By requiring additional documentation and rigorous checks, institutions help deter layering attempts central to transaction chaining.

Implement specialized rule-based triggers and velocity checks to detect consecutive or rapid transactions across multiple accounts or jurisdictions without a clear economic rationale. This includes setting automated thresholds for frequency and value transfers and cross-referencing patterns indicative of peel chains and corridor manipulation. By capturing granular details of each transaction step and timing, institutions can generate real-time alerts for deeper investigation into potential transaction chaining.

Deploy dedicated chain analytics to trace cross-asset bridging, chain hopping, and the use of off-chain or Layer 2 solutions (e.g., the Lightning Network). By identifying high-volume micro-transactions, sudden shifts across multiple blockchains, and attempts to move funds off-chain, institutions can detect efforts to obscure fund origins and escalate promptly for enhanced scrutiny.

Continuously update customer risk profiles by monitoring changes in cross-border transaction frequency, volume, and designated counterparties over time. Investigate abrupt additions of new accounts in multiple jurisdictions and verify the economic basis for these expansions. By promptly escalating suspicious patterns such as peel chains or corridor manipulations, institutions can halt further layering and clarify the true source of funds.

Instruments

  • Criminals open multiple bank accounts across different jurisdictions or financial institutions to conduct sequential wire transfers or deposits in rapid succession.
  • By splitting transactions into smaller sums and distributing them among various accounts, they circumvent typical alerts and threshold reporting, creating a complex transaction chain that frustrates investigators.
  • The ease of initiating cross-border wires via online banking accelerates layering and obscures the ultimate origin of illicit funds.
  • Layering is enhanced by privacy features (e.g., ring signatures, stealth addresses) that obscure both senders and recipients.
  • Illicit funds can be moved from a public chain into privacy coins, then transitioned back to other assets or platforms, making the original source nearly impossible to trace.
  • Criminals execute multiple quick hops in and out of privacy-focused protocols to break transaction linkages, defeating conventional blockchain analytics.
  • Criminals can swiftly generate new wallet addresses for each step of the transaction chain, dispersing illicit funds across numerous addresses.
  • Repeated transfers between wallets, especially in different jurisdictions or through off-chain networks, make it harder to trace fund flows.
  • The pseudonymous nature of many cryptocurrency wallets allows offenders to mask their identities while rapidly layering and moving funds.
IN0027
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  • Offenders convert volatile crypto holdings into stablecoins to maintain consistent value during rapid sequential transfers, preventing large price fluctuations that might raise suspicion.
  • These stablecoins are moved across various platforms and jurisdictions, including Layer 2 or off-chain solutions, making it harder for investigators to track the progression of funds.
  • The ability to quickly swap stablecoins into other digital assets or fiat currencies further cements their role in multi-step transaction chaining.
  • Criminals exploit utility tokens on decentralized platforms to conduct multiple cross-asset swaps, layering illicit funds with minimal regulatory oversight.
  • By rapidly exchanging tokens in different DeFi ecosystems, offenders create complex transaction paths, making it extremely difficult for investigators to follow.
  • The quick issuance and transfer of these tokens facilitate low-value, frequent transactions across permissionless environments, adding layers of obfuscation.
  • Criminals exploit transparent blockchains (e.g., Bitcoin, Ethereum) for quick cross-border transfers, then implement numerous small, consecutive transactions (peel chains) to stay under monitoring thresholds.
  • Rapid movements through multiple addresses and recipients make it difficult to piece together the entire trail, serving the layering goal of transaction chaining.
  • The global accessibility of these cryptocurrencies facilitates transferring funds across jurisdictions in near real-time, complicating law enforcement efforts.
  • Wrapping mechanisms allow criminals to shift funds from one blockchain to another (e.g., Bitcoin to Ethereum as WBTC), obscuring the original chain source.
  • Offenders can swiftly unwrap and re-wrap tokens on multiple networks, generating numerous short-lived addresses and transactions that hamper investigative tracing.
  • This cross-chain approach increases the complexity of transaction chaining, especially when used alongside privacy-enhancing or off-chain tools.

Service & Products

  • Off-chain or Layer 2 platforms (e.g., payment channels) enable high-volume micro-transactions with reduced public visibility.
  • Automated smart contracts allow continuous re-layering, often with limited centralized oversight or KYC requirements.
  • Criminals can exploit weaker KYC/AML controls on P2P platforms to conduct quick, repeated trades that layer illicit proceeds.
  • They orchestrate micro-transactions under reporting thresholds, making it difficult for authorities to detect or trace funds effectively.
  • Facilitates rapid swapping of one cryptocurrency for another without centralized oversight, enabling swift layering cycles.
  • Minimizes transaction traceability as criminals can rotate through multiple coins to further hide origins and destinations.
  • Criminals rapidly convert illicit funds between fiat and cryptocurrencies, repeatedly obscuring transaction trails.
  • Cross-asset trades (“chain hopping”) across multiple exchanges or jurisdictions complicate investigators’ ability to track the ultimate source or destination of funds.
  • Allows seamless transfer of digital assets between different blockchains, helping criminals obfuscate the originating chain of illicit funds.
  • The resulting cross-asset “chain hopping” impedes standardized analytics tools, hindering effective tracing of transactions.
  • Facilitate rapid creation of multiple addresses or wallets to quickly store and transfer funds, speeding up layering.
  • Splitting funds into micro-deposits and withdrawals obscures the overall trail, especially when used alongside other cross-chain or off-chain services.
  • Enables frequent, low-value cross-border transfers, making it harder to piece together the original illicit funds flow.
  • Criminals exploit multiple remittance corridors and micro-transactions to bypass alerting triggers and conceal beneficiary identities.
  • Criminals send funds through rapid sequential wires across multiple banks or jurisdictions, leveraging short transfer times.
  • Splitting large amounts into smaller wires helps evade suspicious transaction thresholds, creating a layered transaction chain.

Actors

  • Provide cross-border wire transfer services for other banks, often processing funds through multiple jurisdictions.
  • Criminals exploit these relationships to rapidly layer transactions, making end-to-end traceability difficult.
  • Financial institutions face challenges in performing effective due diligence when wire transfers hop between numerous correspondent partners.
  • Move illicit proceeds through rapid, successive transactions across multiple jurisdictions.
  • Split funds into smaller amounts to avoid triggering reporting thresholds.
  • Create layered transaction chains that hinder financial institutions' ability to trace ultimate beneficiaries.
  • Facilitate quick conversions between fiat and cryptocurrency, enabling repeated layering or chain hopping.
  • Allow criminals to move funds across multiple jurisdictions through rapid deposits, trades, and withdrawals.
  • Financial institutions face reduced transparency when illicit proceeds continuously hop among exchanges to obscure their origins.
  • Specialize in designing multi-layered transaction chains across both traditional and crypto channels.
  • Use rapid conversions, chain hopping, and micro-transfers to evade reporting triggers.
  • Financial institutions struggle to detect these recurring patterns due to the speed and complexity of layering operations.
  • Maintain accounts that receive and disperse funds within rapid wire or cryptocurrency transaction chains.
  • Present minimal legitimate business activity, yet shift large sums in short intervals.
  • Financial institutions face additional scrutiny and difficulty identifying the true beneficial owners behind these transient corporate structures.
  • Operate decentralized or semi-formal platforms for direct cryptocurrency trades between individuals.
  • Criminals exploit limited KYC procedures by conducting chains of micro-transactions below typical detection thresholds.
  • The fragmented nature of these P2P trades complicates financial institutions' transaction monitoring and ownership verification.
  • Process recurring small remittances or wires that collectively move large illicit sums.
  • Criminals distribute transactions among multiple agents and corridors to circumvent alert thresholds.
  • Financial institutions find it challenging to aggregate all these movements for effective AML monitoring.

References

  1. Akartuna, E. A., Madelin, T. (2022). The state of cross-chain crime: Countering the new age of crypto crime and money laundering in a cross-chain world. Elliptic. https://www.elliptic.co/resources/state-of-cross-chain-crime-report

  2. Whitaker, R. (2024). "What Is a Peel Chain in Crypto Money Laundering?". Merkle Science. https://www.merklescience.com/blog/what-is-a-peel-chain-in-crypto-money-laundering

  3. Layer 2. IQ.wiki. https://iq.wiki/wiki/layer-2