Criminals frequently rotate the registered owners or authorized traders on brokerage accounts (often using multiple nominee names) to conceal the true securities controller, thereby complicating any effort to trace illicit assets through traditional financial oversight. In practice, they often deploy nominee controllers, fake identities, or short-interval substitutions of account signatories, sometimes opening multiple interlinked accounts to obscure beneficial ownership and add layers of complexity. Adversaries exploit markets that do not systematically require current beneficial ownership data, which enables ongoing reshuffling of official records—undermining transparency and forcing investigators to navigate frequent changes of account authority. These tactics also intersect with market manipulation risks (e.g., structuring trades or wash sales under different authorized traders), enabling criminals to launder substantial funds or disguise ill-gotten gains through securities transactions, often underpinned by secrecy-friendly jurisdictions and incomplete ownership registers.
Securities Account Ownership
Tactics
Rotating brokerage account owners or authorized traders, including nominee controllers and fake identities, explicitly obscures the identity of the true securities controller. This practice hinders beneficial ownership transparency and tracing efforts.
Risks
This technique exploits vulnerabilities in identifying true beneficial owners by frequently rotating authorized traders or nominal account holders. Criminals conceal the real controller of securities holdings through nominee names and fake identities, preventing accurate KYC and obscuring ultimate beneficial ownership.
Criminals exploit secrecy-friendly jurisdictions and markets with lax or inconsistent beneficial ownership reporting requirements. By continuously reassigning account authority in these regions, they further erode transparency and hinder cross-border AML investigations.
Indicators
Frequent or repeated changes in the beneficial owner or authorized trader of a securities or brokerage account with no legitimate business rationale.
Frequent, short-interval asset movements between multiple securities or brokerage accounts with no apparent legitimate purpose.
Use of nominee or proxy investors to hold or trade securities in a manner concealing the true beneficial owner.
Multiple securities trading accounts opened under different proxies or front entities lacking legitimate economic activity.
Sudden changes in account control to new entities or individuals lacking a clear business relationship with the previous account holder.
Account holders with ties to secrecy jurisdictions recognized for minimal beneficial ownership disclosure or transparency.
Account holders involved in high-risk or lightly regulated industries (e.g., gambling, cryptocurrency) lacking transparent beneficial ownership.
Sudden changes to the authorized traders or beneficial owners following a significant transaction or regulatory scrutiny.
Complex ownership structures involving multiple layers of entities that obscure the true beneficial owner.
Repeated or cyclical wash trades executed across multiple nominee accounts to manipulate trading volumes or mask true ownership control.
Data Sources
Consolidates AML/CFT risk indicators and beneficial ownership transparency levels across various regions, supporting the detection of:
- Securities accounts tied to secrecy-friendly jurisdictions with minimal disclosure.
- High-risk or lightly regulated industries lacking robust beneficial ownership oversight.
- Multi-jurisdictional setups that obscure the actual controllers behind accounts.
This data enables a risk-based review of complex cross-border structures used in securities account manipulation.
Provides real-time and historical data on various securities, including pricing, volumes, and market trends, to detect:
- Suspicious spikes in trade volumes or abrupt asset flows.
- Unusual price movements suggesting potential manipulation or wash trading.
By comparing actual trading data with normal market conditions, investigators can identify patterns indicative of securities account manipulation and layering activities.
Provides official registration and incorporation data (e.g., shareholders, directors, historical ownership changes), enabling AML teams to detect:
- Nominee or proxy structures obscuring the true beneficial owners of securities accounts.
- Front entities or shell companies lacking legitimate activity.
- Sudden changes in listed signatories or controllers.
- Complex, multi-layer ownership arrangements designed to hide real control.
Leveraging this information helps confirm the authenticity of ownership claims and uncover hidden parties behind securities account manipulation.
Mitigations
Identify and categorize accounts tied to secrecy-friendly jurisdictions where beneficial ownership records may be unreliable. Impose heightened scrutiny or limit services for signatories from these high-risk locations to minimize exposure to repeated or obscured changes in registered control.
Apply deeper scrutiny whenever changes occur in account signatory or beneficial ownership by verifying the identity, source of funds, and legitimacy of each newly appointed individual or entity. This helps expose nominee or proxy structures designed to hide the actual controller behind securities transactions.
At the onboarding stage for securities accounts, collect and verify comprehensive beneficial ownership details and trading authority credentials. Confirm each party’s legitimate connection to the account to reduce the likelihood of hidden or proxy-controlled relationships from the outset.
Implement real-time or periodic analysis of securities account transactions to identify unusual fund flows, especially after changes in authorized traders or beneficial owners. By flagging large or repetitive transfers lacking legitimate justification, institutions can detect layering or surreptitious movement of illicit proceeds.
Provide specialized training for brokerage personnel on red flags associated with frequent rotations of authorized signatories, nominee owners, or unexplained account control substitutions. Equip staff with real case studies and reporting protocols to quickly identify and escalate anomalies indicative of securities account manipulation.
Maintain comprehensive, time-stamped records of all changes to account ownership and authorized traders, including supporting due diligence documentation. This helps auditors and investigators trace patterns of frequent signatory substitutions, identify hidden beneficial owners, and gather evidence of illicit manipulation.
Cross-check newly introduced signatories or beneficial owners using publicly available data, corporate registries, and other external intelligence sources. This process can unmask undisclosed ties among accounts, fabricated identity documents, or repeated use of nominee data to obscure genuine controllers.
Enforce temporary suspensions or controls on account functionality when repeated or unexplained changes in trading authority occur. Require documented justifications for each modification and limit access to sensitive features until due diligence confirms the authenticity and legitimacy of new account holders.
Continuously re-verify beneficial owners and authorized traders throughout the lifetime of the account, particularly following each substitution or addition of new controllers. Investigate patterns of recurrent changes that lack a legitimate business rationale, as these may reveal attempts to conceal the true controlling party.
Scrutinize securities trading activity across interlinked accounts for patterns such as wash trades, circular trading, or market manipulation. Ensure that changes in authorized traders align with legitimate trading rationale to prevent criminals from rotating proxies to conceal or distort illicit securities dealings.
Instruments
- Criminals leverage brokerage accounts holding securities in jurisdictions that do not require strict or updated beneficial ownership reporting.
- They repeatedly change the named account holders or authorized traders, using nominee controllers and fake identities, to obscure who actually controls the securities in these accounts.
- The frequent rotation of signatories or account owners adds layers of complexity, making it harder for financial institutions and regulators to trace illicit proceeds or identify the true beneficial owner.
- This technique supports layering by creating additional transactional steps and documentation changes each time the official account holder is replaced.
Service & Products
- Criminals open or maintain brokerage accounts under multiple nominee names, frequently rotating authorized traders or owners to obscure who controls the securities holdings.
- Rapid or repeated changes to signatories inhibit transparent oversight and delay identification of the true beneficiaries.
- Remote or simplified onboarding processes enable criminals to create multiple accounts under aliases or fictitious names.
- Swift toggling of account permissions and beneficial owners online conceals the true parties behind trades and holdings.
- Nominee directors, trustees, or corporate entities can be formed and substituted on securities accounts, making it difficult to pinpoint the real controllers.
- Layered corporate structures or trusts obscure beneficial ownership, allowing criminals to rotate official account holders repeatedly.
Actors
Brokers facilitate the opening and maintenance of securities accounts, providing access to trading platforms.
- Criminals exploit brokerage relationships by frequently switching account signatories or authorized traders, masking the true controllers.
- This impedes the broker’s ability to conduct effective due diligence and continuous monitoring of account activity.
Illicit operators orchestrate repeated changes of ownership or control for brokerage accounts, often relying on fake identities or proxies.
- By frequently rotating signatories and account names, they obscure who truly directs securities transactions.
- This complicates financial institutions’ efforts to track suspicious activity or identify the ultimate beneficial owners, enabling more effective layering of illicit funds.
Nominees formally appear as the owners or authorized traders on brokerage accounts but lack genuine control or authority.
- Their use conceals the real beneficiaries, distancing the true controllers from suspicious transactions.
- Frequent nominee substitutions hamper financial institutions' ability to identify patterns or trace the underlying source of funds.
Offshore entities registered in secrecy-friendly jurisdictions hold or operate brokerage accounts under lax disclosure requirements.
- Criminals exploit these jurisdictions' limited beneficial ownership obligations to shift official account holders.
- Financial institutions face reduced transparency, making it more difficult to verify the ultimate controlling parties behind securities accounts.
References
FATF (The Financial Action Task Force). (2009, October). Money laundering and terrorist financing in the securities sector. FATF. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Moneylaunderingandterroristfinancinginthesecuritiessector.html
FATF (Financial Action Task Force). (2010, October). Money Laundering Using Trust and Company Service Providers. FATF/OECD and CFATF. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Moneylaunderingusingtrustandcompanyserviceproviders.html
FATF (Financial Action Task Force) - Egmont Group. (2018, July). Concealment of beneficial ownership. FATF. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Concealment-beneficial-ownership.html
FATF (Financial Action Task Force). (2023, March). Guidance on beneficial ownership of legal persons. FATF. http://www.fatf-gafi.org/publications/FATFrecommendations/guidance-beneficial-ownership-legal-persons.html