Criminals capitalize on unregistered or informal economic activities to disguise the origins and magnitude of illicit income, typically by omitting or underreporting these inflows to tax authorities or financial oversight bodies. By presenting these undeclared funds as normal revenue, they evade formal scrutiny and reduce the likelihood of triggering suspicion. In many cases, individuals within the informal sector or complicit accountants help conceal the true source of earnings, either by neglecting to verify supporting documentation or by actively crafting falsified bookkeeping. Once intermingled with legitimate streams, the illicit proceeds can then be deposited into personal or business accounts, ultimately blending into the formal financial system. Research indicates that undeclared earnings can be a major source of dirty funds and that professionals who overlook or assist in misrepresenting these proceeds play a critical role in facilitating money laundering.
Undeclared Earnings
Undeclared Earnings Integration
Tactics
Undeclared earnings are introduced into legitimate financial channels by intermingling illicit inflows with otherwise normal revenues and then depositing them into personal or business accounts. This disguises criminal proceeds as ordinary operating income, thereby reducing immediate detection risks.
Criminals obscure the origin of illicit funds by integrating them into unregistered or informal business proceeds, making them appear as normal revenue.
Risks
Criminals exploit unregistered or informal businesses—entities that lack transparent ownership or reliable documentation—to conceal undeclared earnings outside of formal oversight. By underreporting or omitting income and relying on complicit or negligent accountants, they mask both the sources and true volumes of funds, thereby reducing the likelihood of triggering AML controls linked to customer identity and transactional scrutiny.
Indicators
Customer declines to provide standard business documentation or proof of tax filings during due diligence, claiming the enterprise operates informally.
Business repeatedly fails to produce invoices or receipts to support declared revenue when requested by compliance review teams.
Entity purports ongoing commercial activities yet is absent from official business registries or licensing databases in its stated jurisdiction.
Multiple personal and business accounts—none officially registered—share a single beneficial owner, funneling unverified cash inflows with no apparent legitimate business structure.
Significant discrepancies between amounts declared in official financial statements or tax returns and the actual cash inflows recorded in transaction logs.
Accounting or tax advisory firm consistently endorses or prepares contradictory or incomplete financial statements, indicating potential complicity in underreporting earnings.
Frequent high-value cash deposits labeled as 'business income' from an entity lacking formal registration or tax identification.
Frequent or high-value daily cash deposits into personal accounts, inconsistent with the individual's declared occupation or salary range.
Data Sources
Databases containing official information on the licenses, certifications, and memberships of accounting or tax professionals. This data:
- Confirms whether advisors or accountants endorsing contradictory financial statements are validly licensed.
- Identifies prior disciplinary actions or irregularities, suggesting possible complicity in underreporting earnings.
- Strengthens AML investigations by revealing unqualified or unethical professional involvement facilitating undeclared income.
Includes official financial statements, profit-and-loss records, balance sheets, tax returns, and other formal business documents. This data:
- Allows cross-checking of declared income against actual transaction histories to uncover underreported earnings.
- Identifies significant gaps between reported revenue and observed cash inflows, indicating possible undeclared funds.
- Provides insight into discrepancies within accountant-verified statements, aiming to detect complicit behavior in underreporting.
Encompasses contracts, invoices, receipts, and related documentation, covering payment terms, amounts, and parties involved. This data:
- Validates the source of declared revenue by checking corresponding invoices or receipts.
- Reveals when claimed income lacks any supporting contractual or invoice documentation.
- Detects inconsistencies in amounts or transaction frequency, suggesting unrecorded or fabricated earnings.
Contains records of deposits, withdrawals, transfers, and other account activities, including timestamps, amounts, parties, and transaction identifiers. This data:
- Facilitates comparison between actual cash inflows and the income declared in financial statements or tax filings.
- Flags recurring high-value deposits or transactions inconsistent with an individual's stated occupation or salary range.
- Highlights suspicious patterns of deposits labeled as 'business income' from entities lacking formal registration.
Contains verified identity details, declared occupations, business and ownership information, and documentation gathered during onboarding or ongoing monitoring. This data:
- Verifies the legitimacy and registration status of businesses or individuals claiming informal operations.
- Identifies missing or refused documentation, possibly indicating an attempt to conceal true earnings.
- Checks stated occupation or expected income range against observed transaction flows to detect underreporting.
Provides official registration data, ownership structures, and beneficial owner identities. This data:
- Confirms whether an entity presenting business income is legitimately registered or licensed.
- Identifies multiple unregistered companies sharing the same beneficial owner, suggesting potential funneling of undeclared funds.
- Highlights disparities between purported commercial activities and formal registry information, revealing possible underreporting.
Mitigations
Require deeper scrutiny of customers or businesses exhibiting signs of incomplete or falsified revenue reporting. Verify tax filings, financial statements, and accountant affiliations. Request clarifications on any contradictory or incomplete bookkeeping to uncover underreported income streams.
Require official registration papers, business licenses, and tax identification for all claimed commercial activities during onboarding. Compare the provided documents against government or third-party sources to detect unreported business activities or incomplete financial disclosures.
Implement scenario-based triggers to identify large or repeated cash deposits labeled as 'business revenue' from enterprises that fail to provide valid documentation. Cross-reference transaction flow patterns with the entity’s declared income or tax filings, promptly investigating anomalies indicative of undeclared earnings.
Mandate internal or regulatory reporting for significant cash deposits or high-volume transactions originating from entities lacking formal registration or verifiable income documentation. Retain centralized records of such reports to identify recurring patterns of under-declared revenue over time.
Train front-line staff to identify common indicators of underdeclared or unregistered businesses, such as inconsistent revenue reporting, missing tax registrations, or repeated refusals to provide financial documentation. Emphasize the importance of promptly escalating cases for further investigation.
Search publicly available records, business registries, licensing databases, social media, and news sources to validate the existence and legitimacy of declared businesses. Identify signs of underreporting or informal operations by comparing publicly visible revenue indicators to customer statements or tax filings.
Conduct periodic reviews of customer-reported revenue figures and operational credentials, requesting updated tax filings, invoices, or audited statements. Immediately investigate sudden spikes or changes in declared revenues that may indicate previously concealed or newly undeclared earnings.
Instruments
- Criminals deposit undeclared funds from unregistered or informal business operations into personal or business bank accounts, labeling them as legitimate revenue or personal wages.
- Complicit or negligent accounting practices underreport these deposits, obscuring their true origin from tax authorities and financial regulators.
- Combining illicit and legitimate deposits in the same account makes it harder for institutions to detect abnormalities, as daily revenue patterns or smaller structured deposits appear routine.
- Undeclared earnings often originate as physical currency from informal transactions, remaining off official records.
- Criminals can store these funds in cash and either deposit them gradually below reporting thresholds or mix them with legitimate cash takings.
- The anonymity and difficulty of tracing physical cash enable criminals to bypass formal oversight and avoid disclosing true earnings, reducing the likelihood of triggering suspicion.
Service & Products
- Used to deposit undeclared earnings as normal business income, blending illicit and legitimate funds.
- Facilitates daily transactions that appear legitimate, reducing the likelihood of detection by financial institutions or authorities.
- Criminals deposit undeclared funds in personal accounts, often in smaller increments, to avoid raising red flags.
- These deposits can be disguised as personal savings or wages, helping launder illicit income by making it appear ordinary.
- Criminals rely on complicit accountants or auditors to underreport or omit income, falsely classifying illicit funds as legitimate revenue.
- Inaccurate bookkeeping and falsified financial statements mislead tax authorities, reducing scrutiny and obscuring true fund sources.
Actors
Accountants (including auditors or tax advisors) facilitate undeclared earnings by:
- Overlooking or falsifying financial records, masking the origin and scale of illicit proceeds.
- Assisting clients in underreporting revenue to tax authorities, thus blending illicit funds with legitimate streams.
- Providing misleading financial statements that appear compliant, impairing financial institutions’ ability to identify abnormal patterns or report suspicious activity.
Tax evaders knowingly underreport or omit illicit income from official records, disguising it as legitimate revenue. This underreporting:
- Minimizes scrutiny from tax authorities, as official declarations remain within normal ranges.
- Facilitates the seamless introduction of undeclared funds into the formal banking system by presenting them as ordinary earnings.
- Reduces financial institutions' ability to detect discrepancies between declared income and observed transaction patterns, complicating AML efforts.
References
Molla Imeny, V., Norton, S. D., Salehi, M., Moradi, M. (2020). Taxonomies of money laundering: An Iranian perspective. Journal of Money Laundering Control, Vol. 24 No. 2, pp. 348-360. https://doi.org/10.1108/JMLC-07-2020-0074