Identity Impersonation

Criminals adopt stolen or fabricated personal data, forged documents, and other deceptive practices to pass themselves off as legitimate individuals or organizations, often to bypass KYC/AML checks or seize control of existing financial accounts. This method can serve two ends: enabling the laundering of previously obtained illicit funds under a false identity, or directly acquiring unauthorized access to victim assets by tricking institutions or account holders into surrendering resources. According to one analysis of 2.4 million identity-related suspicious reports, 69% indicated that attackers impersonated businesses, financial institutions, or individuals to commit fraud, demonstrating the prominence of impersonation as the top identity exploitation tactic. Criminals frequently use counterfeit documents (including forged passport cards) to impersonate genuine account holders or authorized representatives, thereby defrauding victims and financial institutions. In some cases, they open and operate bank accounts using falsified foreign identification documents, or pose as officials from legitimate entities to misdirect incoming payments. A related child technique, Remote Identity Deception, exploits online or mobile onboarding processes through altered digital images, manipulated identity documentation, or synthetic data, allowing adversaries to avoid face-to-face verification and operate accounts with minimal scrutiny.

[
Code
T0075
]
[
Name
Identity Impersonation
]
[
Version
1.0
]
[
Parent Technique
]
[
Risk
Customer Risk, Channel Risk
]
[
Created
2025-02-25
]
[
Modified
2025-04-02
]

Identify Theft

Tactics

Identity impersonation is primarily used to bypass KYC/AML checks, secure banking services, and exploit existing accounts under false identities, creating entry points for laundering activities.

Risks

RS0001
|
Customer Risk
|

Criminals steal or fabricate personal and organizational data to pass KYC checks under false identities. By impersonating legitimate customers or beneficial owners, they conceal the true parties controlling financial transactions and undermine accurate customer due diligence.

RS0003
|
Channel Risk
|

The use of remote and digital account onboarding processes with minimal in-person verification is specifically exploited. Impersonators supply falsified credentials online or through mobile channels, bypassing face-to-face scrutiny and making it easier to open or take over accounts under false identities.

Indicators

IND02183
|

Customer-provided identification details do not match records from recognized identity verification sources or official databases.

IND02184
|

Submitted identification documents exhibit signs of tampering, alterations, or inconsistencies with standard official formats.

IND02185
|

Multiple accounts are opened using the same or structurally similar identification documents that fail cross-checks against reliable identity databases.

IND02186
|

Customers display evasive behavior by resisting requests for additional verification when discrepancies in identification data are discovered.

IND02187
|

Frequent modifications to identification details, such as changes in name or address, are observed during periodic customer due diligence updates.

IND02188
|

Newly opened accounts with flagged identification documents initiate unusually large or complex transactions shortly after account creation.

IND02189
|

Multiple newly created accounts, each attributed to distinct individuals, share identical device or IP usage during remote onboarding.

IND02190
|

Account logins originate from locations or IP addresses that conflict with the individual's stated domicile or identity document claims, consistently appearing soon after identity documents are provided.

Data Sources

  • Track device fingerprints, IP addresses, and session metadata to identify repeated usage patterns across supposedly distinct accounts.
  • Detect anomalies in remote onboarding or login behavior to indicate potential impersonation or account takeover.
  • Capture details on transactions (timestamps, amounts, counterparties) to identify unusual or high-risk activity linked to newly created or impersonated accounts.
  • Facilitate pattern analysis to detect abrupt large transactions soon after opening accounts with questionable identity credentials.
  • Aggregate identity information from government registries and commercial data providers to enable the verification of personal and business details.
  • Help identify fictitious or inconsistent records, revealing possible identity impersonation or synthetic identities.
  • Record IP addresses, device identifiers, and login timestamps, highlighting geographic or device inconsistencies with the claimed identity.
  • Provide audit trails to investigate unauthorized sessions and potential misuse of stolen or fabricated credentials.
  • Assesses the authenticity of provided identification documents to detect potential forgeries, tampering, or photo-layering.
  • Facilitates real-time validation of document data fields against official templates and standards, exposing mismatches often seen in impersonation schemes.
DS0033
|
|
  • Collects reported incidents and patterns of identity fraud, including known methods of forging documents or impersonating legitimate customers.
  • Allows cross-referencing of suspicious identity profiles against documented fraud cases.
  • Enhances detection by highlighting recurring impersonation patterns reported within the institution or by industry alerts.
  • Store verified customer identity details, including documents and addresses, to confirm legitimate identity or flag mismatches.
  • Document historical changes or repeated anomalies to expose potential impersonation patterns across multiple accounts.
  • Include emails, phone calls, and chat logs where impersonators might provide conflicting identities or refuse further verification.
  • Enable the review of communication patterns that reveal deceptive arguments or repeated inconsistencies in customer identification.

Mitigations

Escalate to deeper investigations whenever initial checks reveal suspicious or inconsistent identification details. Methods may include validating credentials with government registries, requiring secondary proof of identity (e.g., video interviews), and analyzing IP or device data for unusual login patterns. This specifically identifies and disrupts identity impersonation attempts by imposing stricter verification on high-risk profiles.

Implement robust identity checks at account opening, including automated document scanning, biometric verification, and cross-referencing customer data with official databases to confirm authenticity. This directly combats identity impersonation by detecting forged or stolen documents before an account is fully established.

Require multi-factor authentication for all logins and track device or IP usage in real time. Immediately lock or escalate accounts exhibiting login activity inconsistent with the legitimate owner’s established behavioral profile. This measure prevents identity impersonation by making account takeovers significantly more difficult for fraudsters using stolen credentials.

Equip frontline staff with practical skills to detect counterfeit documents, altered photos, or suspicious customer behavior during onboarding. Provide clear escalation procedures for identity anomalies. This specifically prevents identity impersonation by ensuring personnel recognize red flags and take immediate action on suspicious IDs.

Cross-check customer-provided identity details against publicly available records, social media footprints, and third-party databases. Mismatches or the absence of corroborating information can reveal fabricated or stolen identities. This mitigation directly addresses impersonation by confirming the legitimacy of shared personal data.

Establish partnerships with other financial institutions, law enforcement, and industry consortia to exchange intelligence on known compromised identities, repeat impersonation patterns, and emerging document-forgery techniques. Leveraging collective data helps quickly flag accounts using stolen or fabricated documentation.

Suspend or limit account functions when indicators of identity impersonation emerge, such as tampered ID documents or suspicious login anomalies. Require in-person verification or additional biometrics before restoring functionality. This directly curtails further fraudulent use under a compromised identity.

Continuously re-check and update customer identity records, particularly when personal details or documents change unexpectedly. Investigate any inconsistencies between previously verified data and new submissions. This measure counters identity impersonation by detecting fraudulent updates or evolving deception tactics.

If conclusive evidence of identity fraud is found, terminate the entire customer relationship and all associated accounts. This measure removes impersonators from the financial institution’s ecosystem, preserves compliance, and minimizes the risk of ongoing fraud.

Instruments

  • Criminals submit falsified or stolen identity documents to open new accounts or take over existing ones, bypassing KYC requirements.
  • Once impersonators control an account, they can deposit illicit funds or reroute victim assets under the guise of a legitimate customer.
  • Law enforcement tracing is hampered, as the official records reflect the forged identity rather than the true perpetrator.
  • Criminals register accounts on virtual asset platforms using stolen or synthetic identities, undermining AML/KYC controls.
  • They trade or convert digital currencies while posing as legitimate account holders, obscuring the real ownership and origin of funds.
  • Investigators encounter difficulty linking the transactions to the true perpetrators because the exchange accounts appear validly registered.
  • Using stolen or fabricated personal data, criminals apply for cards or seize control of legitimate card accounts, avoiding direct ties to their real identities.
  • They can then perform fraudulent purchases and cash withdrawals without immediate detection, attributing the transactions to the impersonated individual.

Service & Products

  • Offenders apply for credit cards under false or stolen identities, exploiting banks’ reliance on personal data checks.
  • This allows them to make unauthorized purchases or extract cash advances, leaving legitimate cardholders or institutions to bear the losses.
  • Criminals use stolen or fabricated identity documents to open or take over mobile banking accounts, exploiting remote onboarding processes with limited in-person verification.
  • Once accounts are accessed, they can move or withdraw funds under the impersonated identity without raising immediate suspicion.
  • Criminals register exchange accounts under stolen or synthetic identities, bypassing effective KYC.
  • This enables laundering of illicit proceeds by trading crypto assets under a false persona, complicating traceability and ownership verification.
  • Fraudsters impersonate businesses or authorized representatives to establish merchant accounts, masking the real beneficiaries.
  • Under a stolen identity, they process high volumes of payments to integrate illicit funds into seemingly legitimate transactions.
  • Criminals pose as legitimate individuals using forged identification to open or access remittance accounts.
  • They send or receive funds internationally under the stolen identity, hampering the integrity of KYC checks and obscuring the true beneficiary.
  • Criminals open or hijack checking accounts with counterfeit identification to deposit or transfer illicit proceeds.
  • Account takeovers enable unauthorized fund withdrawals or rerouting of victim assets under the guise of legitimate account holders.
  • Using forged or stolen IDs, criminals register for online-only bank accounts, circumventing in-person identity validation.
  • They conduct transactions under assumed identities, moving funds swiftly while masking their real identity from financial institutions.

Actors

Illicit operators carry out identity impersonation by:

  • Stealing or fabricating personal and organizational data to open or infiltrate financial accounts under false credentials.
  • Gaining unauthorized access to victim funds or laundering illicit proceeds while disguised as legitimate account holders.
  • Misrepresenting themselves during KYC checks, defeating standard due diligence measures.

Document forgers enable identity impersonation by:

  • Creating counterfeit or altered documents, such as passports or corporate records, that criminals use to pass KYC checks.
  • Supplying fraudulent credentials to help impersonators appear legitimate to financial institutions.

This role undercuts accurate customer verification, allowing illicit operators to establish or take over accounts undetected.

References

  1. Financial Crimes Enforcement Network (FinCEN). (2020, July 30). Financial red flag indicators of cybercrime and cyber-enabled crime exploiting COVID-19. FinCEN. https://www.fincen.gov/coronavirus

  2. U.S. Department of the Treasury. (2024). FinCEN notice on the use of counterfeit U.S. passport cards to perpetrate identity theft and fraud schemes at financial institutions. Financial Crimes Enforcement Network (FinCEN). https://www.fincen.gov/

  3. Financial Crimes Enforcement Network (FinCEN). (2024). Identity-related suspicious activity: 2021 threats and trends. FinCEN. https://www.fincen.gov/sites/default/files/shared/FTA_Identity_Final508.pdf

  4. MENAFATF (Middle East & North Africa Financial Action Task Force). (2021, November). MENAFATF Biennial Typologies Report 2020. MENAFATF. http://www.menafatf.org/