Shell companies have legitimate uses and are the workhorses of money laundering structures. Distinguishing legitimate use from front-company abuse is one of the harder KYB calls compliance teams make. This guide covers 10 red flag patterns across address, ownership, operational and document indicators — drawn from FATF, FinCEN and Tax Justice Network case data.
Structuring and smurfing are the foundational placement-stage typologies — and the controls regulators inspect first. This guide covers the definitional difference between the two, six recurring patterns, the behavioural indicators that distinguish structuring from legitimate cash activity, and the limits of threshold-based CTR reporting alone.
Trade-Based Money Laundering exploits the commercial trade system to move illicit value across borders — through over- and under-invoicing, phantom shipments, multiple invoicing, and front-company export schemes. FATF and the Wolfsberg Group both rank TBML among the largest and least-detected money-laundering channels globally. This guide covers the core typologies, the documentary and transactional red flags, and how detection actually works in practice.
The Money Laundering Reporting Officer is the only role in a regulated firm that carries personal regulatory liability for the AML programme. The MLRO decides whether to file Suspicious Activity Reports, approves the firm’s AML policies, and answers directly to the regulator. This guide covers the statutory basis, the practical responsibilities, the reporting-line independence requirements, and the consequences of getting the role wrong.
GDPR and AML obligations operate in parallel, not in conflict. Specific provisions in each framework govern their interaction, with legal bases under UK GDPR explicitly permitting personal data processing for KYC, monitoring, and SAR purposes.
The traditional three-stage model — placement, layering, integration — is necessary but insufficient. Compliance officers must also understand the predicate offence and the concealment mechanisms operating throughout the entire laundering process
