Bank Infrastructure Manipulation

Criminals exploit flaws or blind spots in a bank’s internal systems and transaction-monitoring frameworks by leveraging unpatched security gaps, procedural weaknesses, and loose operational controls. They may misconfigure or override key parameters, allowing illegal funds to flow undetected and bypass mandated AML triggers. In some cases, insider collusion further compromises these controls, as shown by a bank cashier who manipulated internal records to siphon funds from vault holdings. Other examples include systematically altering payment data to conceal sanctioned beneficiaries from intermediary clearing banks. Taken together, these tactics allow criminals to obscure illicit origins, move funds stealthily, and evade compliance safeguards within legitimate banking networks.

[
Code
T0132
]
[
Name
Bank Infrastructure Manipulation
]
[
Version
1.0
]
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Parent Technique
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[
Risk
Internal Risk
]
[
Created
2025-03-12
]
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Modified
2025-04-02
]

Banking Infrastructure Exploitation

Tactics

By exploiting unpatched security gaps, procedural weaknesses, and insider collusion within a bank’s internal systems, criminals deliberately evade compliance safeguards and monitoring controls. This enables them to move illicit funds unnoticed and bypass AML triggers.

Risks

RS0005
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Internal Risk
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Criminals exploit unpatched security gaps, procedural weaknesses, and insider collusion within the bank’s internal systems and governance. By misconfiguring or overriding key controls and transaction parameters, they bypass AML triggers, evade monitoring, and conceal sanctioned beneficiaries, all from within the institution’s own infrastructure.

Indicators

IND01937
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Unauthorized manual overrides of transaction monitoring alerts by staff lacking compliance privileges or documented justification.

IND01939
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Frequent reconfigurations of AML system thresholds without official approval, allowing high-value transfers to pass unflagged.

IND01941
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Unpatched software vulnerabilities in core banking systems enabling the bypass of KYC or CDD protocols.

IND01943
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High-value transactions exceeding normal thresholds failing to trigger alerts after recent unauthorized changes to system parameters.

IND01945
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Significant discrepancy between ledger-reported transaction volumes and those recorded by monitoring systems, indicating data tampering.

IND01946
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Multiple staff accounts accessing administrative functions at unusual hours, coinciding with the deactivation of key security or AML controls.

IND01948
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Failure to apply critical system patches in core banking applications despite official releases, leaving known vulnerabilities unaddressed.

Data Sources

  • Captures patch deployment history, vulnerability scans, and intrusion attempts, revealing gaps where core systems may be exploited.
  • Logs cybersecurity events, such as suspicious network traffic or repeated failed authentication attempts, indicating potential compromise of bank infrastructure.
  • Helps link unpatched software vulnerabilities to observed manipulations of AML or transaction monitoring systems.
  • Document all financial movements and provide details on amounts, timestamps, and originating and destination accounts.
  • Enable comparison of actual transaction activity against configured control thresholds to spot transactions that bypass normal alerts.
  • Help uncover anomalies related to insider suppression of alerts or unauthorized system parameter changes.
  • Includes account balances, ownership information, and transaction histories.
  • Allows validation of core ledger entries against monitoring system records, helping identify tampering or manipulations in reported account activity.
  • Supports detection of discrepancies resulting from unauthorized manual overrides in internal systems.
  • Track user logins, attempted logins, and changes to system configurations (e.g., AML thresholds, security settings).
  • Provide timestamps, user credentials, and activity trails to help investigators detect unauthorized overrides or suspicious after-hours access to administrative functions.
  • Facilitate the identification of insider collusion by correlating access patterns with altered AML triggers or disabled security protocols.
  • Provide detailed information on employees' identities, roles, and internal privileges.
  • Help identify staff with elevated permissions or unusual responsibilities that could facilitate internal system manipulation.
  • Support investigations into potential insider collusion or unauthorized overrides of AML controls within the institution's infrastructure.

Mitigations

Implement automated alerts whenever unusual changes to system parameters or AML thresholds are detected, particularly after business hours or by unauthorized users. Immediately flag and investigate abrupt or repeated reconfigurations that could enable high-value transfers to remain unmonitored, preventing criminals from circumventing established AML triggers.

Enforce robust multi-factor authentication and role-based permissions for any staff accessing AML systems or administrative functions. Maintain continuous logs of system modifications, immediately flagging unauthorized changes to transaction thresholds, security protocols, or monitoring rules. This directly prevents criminals or colluding insiders from covertly manipulating the bank’s infrastructure to launder funds undetected.

Institute mandatory dual authorization for changes to monitoring thresholds or security configurations, with documented approval workflows and segregation of duties. By clearly assigning responsibility for system administration and enforcement, institutions limit opportunities for a single insider to covertly reconfigure AML controls to conceal illicit flows.

Vet all staff, especially those with elevated access to transaction systems or AML controls, for prior criminal or unethical behavior. Ongoing due diligence on employees in sensitive roles helps reduce the risk that collusive insiders will compromise bank infrastructure by overriding or disabling AML measures.

Conduct periodic reviews of patch management, system configurations, and AML rule settings by independent or external auditors. Promptly investigate discrepancies in system logs or unchecked changes, ensuring timely remediation of any weaknesses. This early detection mechanism helps expose insider collusion or infrastructure manipulation before criminals fully exploit internal control gaps.

Establish secure, anonymous whistleblower channels for employees to report attempts to override compliance safeguards. Provide clear escalation steps to ensure that suspected insider collusion, unusual system reconfigurations, and suspicious manipulation of transaction data are swiftly investigated. This promotes early detection of compromised internal systems.

Implement mandatory patch management policies and conduct regular security assessments to close exploitable gaps in core banking systems. Encrypt sensitive data and maintain secure network configurations to prevent manipulation of transaction logs or the override of AML triggers. These controls reduce the risk of criminals exploiting unpatched software vulnerabilities or misconfigurations to bypass monitoring frameworks.

Instruments

  • Criminals exploit misconfigured or overridden transaction-monitoring thresholds tied to bank accounts, enabling illicit funds to move undetected.
  • By colluding with insider staff or abusing system vulnerabilities, they can bypass alerts or falsify data entries, hiding unusual volumes and suspicious transactions.
  • This manipulation leverages legitimate bank infrastructure to obscure ultimate beneficiaries and fund origins, evading standard AML checks.
IN0051
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  • Insiders, such as vault custodians, can siphon physical currency from bank vaults while manipulating internal ledgers to avoid detection.
  • Weak reconciliation or oversight allows large cash discrepancies to go unflagged, undermining typical AML controls.
  • Once removed, cash remains largely untraceable, making it easy to conceal illicit origins and evade official scrutiny.

Service & Products

  • Colluding employees (e.g., tellers or vault custodians) can falsify internal records, siphoning funds from vault holdings without triggering alerts.
  • Gaps in oversight or reconciliation procedures enable unauthorized cash removals to remain unflagged within the bank’s infrastructure.
  • Criminals exploit or misconfigure internal wire messaging fields (e.g., SWIFT fields) to hide sanctioned beneficiaries or suspicious payment details.
  • By overriding transaction-monitoring parameters, they bypass AML triggers, enabling large or high-risk transfers to flow undetected.
  • Insiders or colluding staff can manipulate the cross-border transaction chain, preventing automated screening or flagging of illicit transfers.
  • This misuse conceals true beneficial owners or sanctioned parties, leveraging weaknesses in intermediary clearing points to evade detection.

Actors

These employees are knowingly or unknowingly involved by:

  • Overriding transaction monitoring or security alerts without proper authorization.
  • Altering system parameters to allow high-risk transactions to go unflagged.
  • Manipulating internal records (e.g., vault holdings) and facilitating illicit asset transfers.

Intermediary clearing banks are unwittingly exploited when criminals alter or conceal payment details before transactions reach them, preventing automated screening from identifying sanctioned parties. Colluding staff within the originating bank’s infrastructure may mask or remove critical information, enabling cross-border wires to pass undetected.

They exploit unpatched vulnerabilities or procedural weaknesses within the bank’s systems to launder illicit funds. They may:

  • Bribe or collude with insiders to override AML controls.
  • Manipulate transaction or payment data to conceal sanctioned beneficiaries.
  • Leverage flawed system configurations to move large sums undetected.

References

  1. Goldbarsht, D., de Koker, L. (2022). Financial Technology and the Law: Combating Financial Crime. Springer. https://doi.org/10.1007/978-3-030-88036-1

  2. APG (Asia/Pacific Group on Money Laundering) Typologies Working Group. (2005, June). APG Yearly Typologies Report 2004-05. APG (Asia/Pacific Group on Money Laundering). https://www.amlo.go.th/amlo-intranet/media/k2/attachments/TypologiesZReportZ04-05.pdf

  3. Platt, S. (2015). Criminal Capital: How the Finance Industry Facilitates Crime. Palgrave Macmillan. https://doi.org/10.1057/9781137337306