AML Judgment Gap Report · Full findings
Retail and Commercial Banking
This is a specimen. The cases, the weights, the methods and the sources are real, and are what your team would sit and what your own report would cite. The scores are invented, for a hypothetical cohort of 14 people. A real report carries your own results and nothing else.
Your team detects 15 of the 68 money laundering methods that apply to this sector. 15 need action, and 5 of those are rarely covered by standard training.
2 of these are urgent. Your team was tested on them and missed them.
Your assessment is 23 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 68 methods each one carries. Measured against the methods that apply to this sector, not against other firms.
Since the last sitting
September cohort against March cohort. Your team detected 14 methods then and 15 now. 14 went backwards.
What to do
For each one, ask a single question. Does the team not know the method, or do they know it and have no rule that would surface it? The first needs a briefing. The second is a control gap, and it is the more serious answer.
- High
- Tested and missed, on a case covering a large part of your exposure.
- Medium
- Tested and missed on a smaller case, or never tested on one that matters.
- Low
- Never tested, and a small part of your exposure.
Ordered by priority. The reason for each is printed with it, so you can disagree with the ranking.
- 01
Agentic Laundering and Automated Smurfing
HighYour team was tested on this and missed it. It sits in The Verification Desk, which covers 9 of the 68 methods that apply to you. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Verification Desk — covers 9 of your 68 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Transaction sequences with machine timing and sizing characteristics, activity that reshapes itself shortly after a control is changed, and volumes of small movements that exceed what any manual operation could sustain.
90 days · Re-testSit The Verification Desk again, on the version the team has not seen.
OwnerTarget date - 02
Laundering and Fraud as a Service
HighYour team was tested on this and missed it. It sits in The Verification Desk, which covers 9 of the 68 methods that apply to you. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Verification Desk — covers 9 of your 68 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
The same tooling signature across customers with no other connection: identical document templates, shared device or capture characteristics, and mule accounts appearing in coordinated batches rather than individually.
90 days · Re-testSit The Verification Desk again, on the version the team has not seen.
OwnerTarget date - 03
Capital-Flight Invoicing with Genuine Goods
MediumYour team was tested on this and missed it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Offshore receipt accounts holding balances well above production cost, cover purchases of high-value goods with no commercial logic, and settlement rates away from market.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 04
Counterfeit Goods and IP Crime Proceeds
MediumYour team was tested on this and missed it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Merchant accounts with high chargeback and dispute rates against a narrow product range, settlement to beneficiaries unrelated to the listed merchant, and rapid rotation of storefronts under the same banking relationship.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 05
Dual-Use Goods Diversion
MediumYour team was tested on this and missed it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Sudden growth in trade finance for electronics and machinery through transhipment jurisdictions, buyers incorporated after the export controls took effect, and end-user statements inconsistent with the buyer's business.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 06
High-Value Portable Goods
MediumYour team was tested on this and missed it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Dealer accounts taking third-party payments for goods delivered to someone else, part-exchange chains that never settle in cash, and customers whose purchases exceed any evidenced income.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 07
Illicit Excise Goods and Diversion
MediumYour team was tested on this and missed it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Wholesale accounts with purchase volumes inconsistent with declared duty, rapid movement of goods between connected traders, and cash takings at retail exceeding what the site can support.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 08
Mirror Transfers and Daigou Purchasing
MediumYour team was tested on this and missed it. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 68 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Card accounts repaid in cash or by unrelated third parties, purchase volumes far exceeding personal use, and paired domestic flows in two jurisdictions with no instrument connecting them.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 09
MTIC and VAT Carousel Fraud
MediumYour team was tested on this and missed it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Rapid high-value trading between newly incorporated counterparties in the same goods, payments that pass through in hours, margins too thin to support the businesses, and directors with no trading history in the sector.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 10
Mirror and Arbitrage Trading
MediumYour team was tested on this and missed it.
- Result
- Caught 50% of the laundering customer's alerts.
- Tested by
- The Securities Book — covers 3 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Customers whose trades consistently lose money on fees and spreads, identical baskets bought and sold across branches, and no economic rationale beyond currency conversion.
90 days · Re-testSit The Securities Book again, on the version the team has not seen.
OwnerTarget date - 11
State-Owned Entity Exemption Abuse
MediumYour team was tested on this and missed it. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 50% of the laundering customer's alerts.
- Tested by
- The Securities Book — covers 3 of your 68 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Due diligence closed out on an assertion of state ownership, and transaction volumes exceeding the plausible revenue of the entity the name resembles.
90 days · Re-testSit The Securities Book again, on the version the team has not seen.
OwnerTarget date - 12
Child Sexual Exploitation Payment Patterns
MediumYour team was tested on this and missed it. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 36% of the laundering customer's alerts.
- Tested by
- The Payment Trail — covers 2 of your 68 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Small repeated payments, often at unusual hours, to money transfer beneficiaries in a small number of jurisdictions with no family or trade connection to the customer; use of prepaid instruments or virtual assets by a customer with no other digital activity; and payment values clustered in narrow bands.
90 days · Re-testSit The Payment Trail again, on the version the team has not seen.
OwnerTarget date - 13
Sport Ownership and Sponsorship
MediumYour team was tested on this and missed it.
- Result
- Caught 39% of the laundering customer's alerts.
- Tested by
- The Sponsorship File — covers 2 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Club funding by shareholder loan from opaque structures, sponsorship values with no commercial benchmark, agent and image-rights payments routed through unrelated jurisdictions, and transfer fees inconsistent with market.
90 days · Re-testSit The Sponsorship File again, on the version the team has not seen.
OwnerTarget date - 14
Fabricated Rental Income and Ghost Tenants
MediumYour team was tested on this and missed it.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 2 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Rent credits inconsistent with occupancy or utility data, tenants who never pay late, and payments originating from accounts connected to the landlord.
90 days · Re-testSit The Private Client File again, on the version the team has not seen.
OwnerTarget date - 15
Investment Migration and Residence Schemes
MediumYour team was tested on this and missed it.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 2 of your 68 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Source of wealth evidenced principally by the qualifying investment itself, onboarding shortly after grant of status, and jurisdiction of residence inconsistent with any economic or family connection.
90 days · Re-testSit The Private Client File again, on the version the team has not seen.
OwnerTarget date
On your own report
Each line carries your team’s result, an owner and a date. The re-test at 90 days shows what has moved.
Appendix
Evidence
Everything the finding above rests on, for anyone who wants to check it.
By case
The 23 cases that make up your assessment. Detection rate is the share of the laundering customer’s alerts the team caught. The last column counts people who escalated everything, which catches the laundering customer without deciding anything and scores badly for that reason.
| Case | Your methods | Share of assessment | Runs | Median mark | Detection rate | Escalated everything |
|---|---|---|---|---|---|---|
| The Verification Desk | 9 | 13% | 14 | 49 | 46% | 3 of 14 |
| The Client Engagement | 8 | 8% | 14 | 87 | 84% | 3 of 14 |
| The Client Account | 7 | 7% | 14 | 80 | 77% | 3 of 14 |
| The Goods Chain | 7 | 7% | 14 | 45 | 42% | 2 of 14 |
| The Policy Book | 7 | 7% | 14 | 87 | 83% | 3 of 14 |
| The Relationship Review | 7 | 7% | 14 | 50 | 46% | 2 of 14 |
| The Betting Account | 6 | 6% | 14 | 67 | 63% | 2 of 14 |
| The Collection Network | 4 | 4% | 14 | 61 | 57% | 2 of 14 |
| The Funnel Account | 4 | 4% | 14 | 78 | 76% | 2 of 14 |
| The Incoming Payment | 4 | 4% | 14 | 69 | 65% | 3 of 14 |
| The Trade Corridor | 4 | 4% | 14 | 66 | 64% | 2 of 14 |
| The Victim Ledger | 4 | 4% | 14 | 79 | 76% | 2 of 14 |
| The Alert Queue | 3 | 3% | 14 | 82 | 79% | 3 of 14 |
| The Exchange Desk | 3 | 3% | 14 | 69 | 66% | 3 of 14 |
| The Merchant Book | 3 | 3% | 14 | 59 | 57% | 4 of 14 |
| The Securities Book | 3 | 3% | 14 | 53 | 50% | 3 of 14 |
| The Fundraising Appeal | 2 | 2% | 14 | 65 | 63% | 3 of 14 |
| The Disclosure | 2 | 2% | 14 | 85 | — | — |
| The Onboarding Interview | 2 | 2% | 14 | 87 | — | — |
| The Payment Trail | 2 | 2% | 14 | 39 | 36% | 2 of 14 |
| The Private Client File | 2 | 2% | 14 | 48 | 45% | 4 of 14 |
| The Sponsorship File | 2 | 2% | 14 | 42 | 39% | 3 of 14 |
| The Invoice Pack | 1 | 1% | 14 | 37 | — | — |
Every method
All 68 methods that apply to this sector, and where each one is documented. Full citations are at amlbenchmark.com/coverage.
| Method | Case | Rate | Result |
|---|---|---|---|
| Agentic Laundering and Automated Smurfingrarely trainedTRM Labs, Autonomous AI Agents and Financial Crime (2026), identifying layering as the stage most susceptible to automation… | The Verification Desk | 46% | Missed |
| Child Sexual Exploitation Payment Patternsrarely trainedFinCEN Notice FIN-2021-NTC3 (16 September 2021) on identifying and reporting suspicious activity related to online child sexual… | The Payment Trail | 36% | Missed |
| Laundering and Fraud as a Servicerarely trainedFATF, Professional Money Laundering (26 July 2018), describing professional launderers, organisations and networks that launder… | The Verification Desk | 46% | Missed |
| Mirror Transfers and Daigou Purchasingrarely trainedFinCEN advisory on Chinese Money Laundering Networks (28 August 2025), identifying mirror transactions, money mules and… | The Goods Chain | 42% | Missed |
| State-Owned Entity Exemption Abuserarely trainedOCCRP, The Azerbaijani Laundromat (September 2017): approximately US$2.9bn (€2.5bn) moved over two years through four shell… | The Securities Book | 50% | Missed |
| Capital-Flight Invoicing with Genuine GoodsGlobal Financial Integrity research on trade misinvoicing | The Goods Chain | 42% | Missed |
| Counterfeit Goods and IP Crime ProceedsEUIPO and OECD, Mapping Global Trade in Fakes 2025 | The Goods Chain | 42% | Missed |
| Dual-Use Goods DiversionUnited States v Mazulina: on 24 June 2026 a federal court in Brooklyn sentenced the former western regional manager of freight… | The Goods Chain | 42% | Missed |
| Fabricated Rental Income and Ghost TenantsLetting agency businesses were brought into the UK regulated sector by the Money Laundering and Terrorist Financing (Amendment)… | The Private Client File | 45% | Missed |
| High-Value Portable GoodsHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraphs… | The Goods Chain | 42% | Missed |
| Illicit Excise Goods and DiversionHMRC alcohol strategy and enforcement against inward diversion fraud | The Goods Chain | 42% | Missed |
| Investment Migration and Residence SchemesEuropean Commission v Malta (CJEU, Case C-181/23, judgment of 29 April 2025), holding that Malta's… | The Private Client File | 45% | Missed |
| Mirror and Arbitrage TradingNYDFS consent order with Deutsche Bank (30 January 2017), US$425m, and FCA Final Notice, £163m, concerning mirror trades that… | The Securities Book | 50% | Missed |
| MTIC and VAT Carousel FraudEuropean Public Prosecutor's Office, 5 May 2026: a businessman was arrested in Italy for laundering and reinvesting the proceeds… | The Goods Chain | 42% | Missed |
| Sport Ownership and SponsorshipHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraphs… | The Sponsorship File | 39% | Missed |
| AI-Fabricated Corporate Presencerarely trainedDue diligence industry reporting on generative AI lowering the cost of fabricating a corporate identity — website, product… | The Merchant Book | 57% | Partial |
| Biometric Injection and Liveness Bypassrarely trainedGroup-IB, Weaponized AI (January 2026), documenting 8,065 biometric injection attempts against the digital loan onboarding of a… | The Betting Account | 63% | Partial |
| Correspondent Banking and Nested Downstream Accessrarely trainedWolfsberg Group Principles for Correspondent Banking (2022) and the Correspondent Banking Due Diligence Questionnaire, the de… | The Trade Corridor | 64% | Partial |
| Cuckoo Smurfingrarely trainedKalimuthu v Commissioner of the Australian Federal Police [2019] HCA 39 | The Funnel Account | 76% | Partial |
| Doppelganger Accounts Across Institutionsrarely trainedEconomic Crime and Corporate Transparency Act 2023, sections 188 and 189, in force 15 January 2024 | The Funnel Account | 76% | Partial |
| Engineered Litigation and Court-Ordered Settlementrarely trainedOCCRP, The Russian Laundromat: approximately US$20bn moved between 2010 and spring 2014 through a core of 21 shell companies… | The Client Account | 77% | Partial |
| Environmental Crime Proceedsrarely trainedUS Treasury (OFAC) press release of 25 June 2026 designating Gasabo Gold Refinery LTD of Kigali, its chairman and general… | The Trade Corridor | 64% | Partial |
| Ghost Companies: struck off but still transactingrarely trainedNCA, 16 July 2025: 11,500 UK companies struck off the Companies House register following a multi-agency operation with Companies… | The Client Account | 77% | Partial |
| Gold, Refining and Free-Trade Zonesrarely trainedUS Treasury (OFAC) press release of 25 June 2026 designating Gasabo Gold Refinery LTD of Kigali, its chairman Jean Malic Kalima… | The Trade Corridor | 64% | Partial |
| Guarantee Marketplaces and Criminal Service Platformsrarely trainedFinCEN finding that Cambodia-based Huione Group is a foreign financial institution of primary money laundering concern under… | The Victim Ledger | 76% | Partial |
| Human Trafficking and Modern Slavery Proceedsrarely trainedFinCEN Advisory FIN-2020-A008, Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity (15… | The Funnel Account | 76% | Partial |
| Real Estate: engineered foreclosure and retained controlrarely trainedFinCEN's Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule, in force 1 March 2026 after a postponement… | The Client Account | 77% | Partial |
| Shadow Fleet and Maritime Sanctions Evasionrarely trainedThe G7 price cap on Russian crude, in force since December 2022 | The Trade Corridor | 64% | Partial |
| State-Actor Cyber Theft and Launderingrarely trainedBybit, 21 February 2025: approximately US$1.5bn in Ethereum stolen, attributed by the FBI to North Korean actors under the… | The Exchange Desk | 66% | Partial |
| State-Sponsored IT Worker Payroll Infiltrationrarely trainedOFAC designations targeting DPRK IT worker facilitation, including Sim Hyon Sop of Korea Kwangson Banking Corporation (April… | The Incoming Payment | 65% | Partial |
| Streaming, Licensing and Royalty Flowsrarely trainedSvenska Dagbladet investigation (2023) in which four Swedish gang members and a police investigator described converting proceeds… | The Incoming Payment | 65% | Partial |
| Synthetic and AI-Generated Onboarding Documentsrarely trainedFinCEN Alert FIN-2024-Alert004 (13 November 2024) on fraud schemes using generative AI to circumvent identity verification… | The Exchange Desk | 66% | Partial |
| Synthetic Identities at Scalerarely trainedUS Federal Reserve payments-improvement material on the transformation of synthetic identity fraud by generative AI; industry… | The Betting Account | 63% | Partial |
| Terrorist Financing: small-value and fundraisingrarely trainedFATF, Comprehensive Update on Terrorist Financing Risks (July 2025) | The Fundraising Appeal | 63% | Partial |
| Virtual IBAN Misuserarely trainedFCA expectations that firms offering vIBANs hold adequate systems and controls | The Merchant Book | 57% | Partial |
| Bulk Cash Smuggling and Cash CouriersNCA press release of 28 May 2026 on a cross-border investigation across the island of Ireland: six arrests in Cookstown and the… | The Collection Network | 57% | Partial |
| Control Probing and Detection-Threshold DiscoveryAnalytic pattern rather than a single reported case | The Betting Account | 63% | Partial |
| Crypto ATMs and OTC BrokersR v Osunkoya: the FCA's first criminal prosecution for unregistered cryptoasset activity under the Money Laundering Regulations… | The Victim Ledger | 76% | Partial |
| Gambling and Betting Channel MisuseGambling Commission, Money laundering and terrorist financing risks within the British gambling industry (2026 assessment… | The Betting Account | 63% | Partial |
| Hawala and Informal Value TransferEuropol-coordinated action against a parallel-banking network, executed January 2025 and announced May 2025: 17 arrests across… | The Collection Network | 57% | Partial |
| Investment and Romance Scam Proceeds InfrastructureUS and UK joint action of 15 October 2025 against the Cambodia-based Prince Group transnational criminal organisation: OFAC… | The Victim Ledger | 76% | Partial |
| Legal and Accountancy Client Account MisuseThe Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), made 9 June 2026 and in force 30 June… | The Client Account | 77% | Partial |
| Migrant Smuggling SettlementEuropol-coordinated action executed January 2025 and announced May 2025 against a parallel-banking network laundering over €21m… | The Funnel Account | 76% | Partial |
| Money Mule Networks and RecruitmentFCA multi-firm review of firms' use of the National Fraud Database and mule detection tools | The Betting Account | 63% | Partial |
| Mortgage and Property Finance FraudUK Finance, Mortgage Fraud: Good Practice Guidance Note; the FCA's mortgage fraud reporting scheme for lenders and advisers, and… | The Client Account | 77% | Partial |
| Mule Collection and Threshold ConsolidationNCA UK Financial Intelligence Unit, SARs in Action — Money Mules special edition (October 2023), covering mule networks as… | The Alert Queue | 79% | Partial |
| Nested Payment InstitutionsFCA portfolio letter to payments firms (3 February 2025) on financial crime controls, governance and safeguarding | The Alert Queue | 79% | Partial |
| Online Marketplaces and Controlled ResaleEuropol coordinated e-commerce fraud operations (the eCommerce Action series) and its takedowns of marketplaces trading illegally… | The Merchant Book | 57% | Partial |
| Prepaid Cards, Gift Cards and Stored ValueHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraph… | The Betting Account | 63% | Partial |
| Public Funding and Support Scheme FraudInsolvency Service enforcement on Bounce Back Loan Scheme abuse: 1,036 directors disqualified in 2024-25, of which 736 related to… | The Incoming Payment | 65% | Partial |
| Ransomware Proceeds ConversionOFAC designation of 2 June 2026 of Nobitex, Iran's largest virtual currency exchange, together with Wallex, Bitpin and Ramzinex… | The Victim Ledger | 76% | Partial |
| Services Invoicing with No DeliverableFATF and Egmont Group, Trade-Based Money Laundering: Trends and Developments (December 2020), and the companion FATF Trade-Based… | The Invoice Pack | — | Partial |
| Unhosted Wallets and Fragmented Off-RampingFATF, Targeted Report on Stablecoins and Unhosted Wallets: Peer-to-Peer Transactions (3 March 2026) | The Exchange Desk | 66% | Partial |
| Accounts Prepared to Legitimise Falsified Recordsrarely trainedHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraph… | The Client Engagement | 84% | Detected |
| Deepfake-Enabled Payment Instruction Fraudrarely trainedArup, Hong Kong (January 2024): 15 transfers totalling approximately HK$200m (about US$25.6m) executed in a single day after a… | The Policy Book | 83% | Detected |
| Insolvency as a Laundering Endpointrarely trainedHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraph… | The Client Engagement | 84% | Detected |
| Insurance Product Misuserarely trainedFATF, Guidance for a Risk-Based Approach for the Life Insurance Sector (October 2018), developed with the private sector; and… | The Policy Book | 83% | Detected |
| Loan-Back Arrangementsrarely trainedFATF, Professional Money Laundering (July 2018) | The Client Engagement | 84% | Detected |
| Mini-Umbrella Company Fraudrarely trainedElphysic Ltd & Ors v HMRC [2025] UKUT 236 (TCC), 17 July 2025: the Upper Tribunal upheld HMRC's VAT deregistration of… | The Client Engagement | 84% | Detected |
| Necrofinance: dead directors and zombie accountsrarely trainedICIJ Panama Papers investigation (2016) into Mossack Fonseca | The Policy Book | 83% | Detected |
| Synthetic Voice Against Telephone and Callback Controlsrarely trainedFinCEN Alert FIN-2024-Alert004 (13 November 2024), whose red flags cover GenAI-assisted impersonation used to circumvent identity… | The Policy Book | 83% | Detected |
| Beneficial Ownership ObfuscationThe two largest beneficial ownership regimes moved in opposite directions within a year, and a structure is now easier to hide in… | The Policy Book | 83% | Detected |
| Bribery Conduits and Consultancy PaymentsOperation Lava Jato: in December 2016 Odebrecht and Braskem admitted paying approximately US$788m in bribes to officials across a… | The Policy Book | 83% | Detected |
| Cash-Intensive Front BusinessFCA v National Westminster Bank (2021): £264.8m criminal penalty over the Fowler Oldfield account | The Client Engagement | 84% | Detected |
| Charity and Non-Profit AbuseFATF Recommendation 8, amended at the October 2023 Plenary to require risk-based rather than blanket measures, and the… | The Client Engagement | 84% | Detected |
| Sanctions-Evasion Ownership RestructuringOFSI and FCDO joint guidance on the meaning of ownership and control under UK sanctions, issued following Mints v National Bank… | The Policy Book | 83% | Detected |
| TCSPs and Professional EnablersThe Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), made 9 June 2026 and in force 30 June… | The Client Engagement | 84% | Detected |
| Turnover Inconsistency Against a Physical MeasureAnalytic pattern rather than a single reported case: declared turnover tested against an independent physical measure of activity | The Client Engagement | 84% | Detected |
How this was measured
Each case is built around one customer who is laundering money. The rate is the share of that customer’s alerts the team caught.
- Detected
- Four fifths of them or more.
- Partial
- Between a half and four fifths.
- Missed
- Half or fewer.
- Untested
- No one has sat a case covering it.
Nothing is reported as detected on the strength of a good overall mark. Findings are suppressed below 3 runs on a case, because a smaller number describes one analyst rather than a team. Methods are declared on the case, not the individual alert, so this reports whether the team detected the method a case is built around rather than scoring each method separately.