AML Judgment Gap Report · Full findings
Capital Markets and Brokerage
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 5 of the 9 money laundering methods that apply to this sector. 4 need action, and 1 of those are rarely covered by standard training.
4 of these are urgent. Your team was tested on them and missed them.
Your assessment is 5 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 9 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 2 methods then and 5 now. 2 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
Crowdfunding with Controlled Investors
HighYour team was tested on this and missed it. It sits in The Securities Book, which covers 5 of the 9 methods that apply to you.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Securities Book — covers 5 of your 9 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?
Platform settlements to a venture with no product history, funding concentrated among connected contributors, and a rapid orderly wind-up.
90 days · Re-testSit The Securities Book again, on the version the team has not seen.
OwnerTarget date - 02
Mirror and Arbitrage Trading
HighYour team was tested on this and missed it. It sits in The Securities Book, which covers 5 of the 9 methods that apply to you.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Securities Book — covers 5 of your 9 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 - 03
Private Placements and Subscription-as-Payment
HighYour team was tested on this and missed it. It sits in The Securities Book, which covers 5 of the 9 methods that apply to you.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Securities Book — covers 5 of your 9 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?
Subscription monies from investors with no investment profile, funds with no genuine strategy, and redemptions issued as cards or transfers in unrelated jurisdictions.
90 days · Re-testSit The Securities Book again, on the version the team has not seen.
OwnerTarget date - 04
State-Owned Entity Exemption Abuse
HighYour team was tested on this and missed it. It sits in The Securities Book, which covers 5 of the 9 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 Securities Book — covers 5 of your 9 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
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 5 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 Securities Book | 5 | 39% | 14 | 49 | 46% | 3 of 14 |
| The Trade Corridor | 3 | 23% | 14 | 87 | 84% | 3 of 14 |
| The Policy Book | 2 | 15% | 14 | 87 | 83% | 3 of 14 |
| The Relationship Review | 2 | 15% | 14 | 50 | 46% | 2 of 14 |
| The Onboarding Interview | 1 | 8% | 14 | 87 | — | — |
Every method
All 9 methods that apply to this sector, and where each one is documented. Full citations are at amlbenchmark.com/coverage.
| Method | Case | Rate | Result |
|---|---|---|---|
| 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 | 46% | Missed |
| Crowdfunding with Controlled InvestorsFATF, Crowdfunding for Terrorism Financing (October 2023) | The Securities Book | 46% | 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 | 46% | Missed |
| Private Placements and Subscription-as-PaymentFINRA Regulatory Notice 23-08 (2023) on broker-dealer responsibilities in private placements, and FINRA Rule 3110 requiring… | The Securities Book | 46% | Missed |
| 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 | 84% | Detected |
| 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 | 84% | Detected |
| Shadow Fleet and Maritime Sanctions Evasionrarely trainedThe G7 price cap on Russian crude, in force since December 2022 | The Trade Corridor | 84% | 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 |
| 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 |
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.