Payments, EMIs and Acquiring

Since the last sitting

September cohort against March cohort. Your team detected 4 methods then and 12 now. 10 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.

1. 01

   Agentic Laundering and Automated Smurfing

   High

   Your team was tested on this and missed it. It sits in The Verification Desk, which covers 9 of the 41 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 41 methods

   Training

   Rarely covered by standard annual refreshers

   Now · Brief

   Send the team the register entry. It has the mechanism, the signal and the sources.

   30 days · Control

   Which 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-test

   Sit The Verification Desk again, on the version the team has not seen.

   OwnerTarget date
2. 02

   Laundering and Fraud as a Service

   High

   Your team was tested on this and missed it. It sits in The Verification Desk, which covers 9 of the 41 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 41 methods

   Training

   Rarely covered by standard annual refreshers

   Now · Brief

   Send the team the register entry. It has the mechanism, the signal and the sources.

   30 days · Control

   Which 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-test

   Sit The Verification Desk again, on the version the team has not seen.

   OwnerTarget date
3. 03

   Child Sexual Exploitation Payment Patterns

   Medium

   Your 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 41 methods

   Training

   Rarely covered by standard annual refreshers

   Now · Brief

   Send the team the register entry. It has the mechanism, the signal and the sources.

   30 days · Control

   Which 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-test

   Sit The Payment Trail again, on the version the team has not seen.

   OwnerTarget date
4. 04

   Counterfeit Goods and IP Crime Proceeds

   Medium

   Your team was tested on this and missed it.

   Result

   Caught 42% of the laundering customer's alerts.

   Tested by

   The Goods Chain — covers 2 of your 41 methods

   Now · Brief

   Send the team the register entry. It has the mechanism, the signal and the sources.

   30 days · Control

   Which 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-test

   Sit The Goods Chain again, on the version the team has not seen.

   OwnerTarget date
5. 05

   Mirror Transfers and Daigou Purchasing

   Medium

   Your 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 2 of your 41 methods

   Training

   Rarely covered by standard annual refreshers

   Now · Brief

   Send the team the register entry. It has the mechanism, the signal and the sources.

   30 days · Control

   Which 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-test

   Sit The Goods Chain again, on the version the team has not seen.

   OwnerTarget date
6. 06

   Crowdfunding with Controlled Investors

   Medium

   Your team was tested on this and missed it.

   Result

   Caught 50% of the laundering customer's alerts.

   Tested by

   The Securities Book — covers 1 of your 41 methods

   Now · Brief

   Send the team the register entry. It has the mechanism, the signal and the sources.

   30 days · Control

   Which 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-test

   Sit The Securities Book again, on the version the team has not seen.

   OwnerTarget date