AML Judgment Gap Report · Full findings
Wealth and Private 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 11 of the 19 money laundering methods that apply to this sector. 6 need action, and 2 of those are rarely covered by standard training.
One of these is urgent. Your team was tested on it and missed it.
Your assessment is 13 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 19 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 9 methods then and 11 now. 6 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
Estate Administration and Probate
HighYour team was tested on this and missed it. It sits in The Relationship Review, which covers 8 of the 19 methods that apply to you. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Relationship Review — covers 8 of your 19 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?
Estate funds arriving from a professional's client account with no visibility of their origin; assets appearing in an estate that the deceased's known circumstances do not explain; and a firm that is itself the executor, where no external party sees the administration at all.
90 days · Re-testSit The Relationship Review again, on the version the team has not seen.
OwnerTarget date - 02
Art and Antiquities: self-dealing at auction
MediumYour team was tested on this and missed it. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 3 of your 19 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?
Auction proceeds from a sale where consignor and buyer are ultimately the same interest, and valuations resting entirely on expert opinion where no non-destructive dating is possible.
90 days · Re-testSit The Private Client File again, on the version the team has not seen.
OwnerTarget date - 03
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 3 of your 19 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 - 04
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 19 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 - 05
Private Placements and Subscription-as-Payment
MediumYour team was tested on this and missed it.
- Result
- Caught 50% of the laundering customer's alerts.
- Tested by
- The Securities Book — covers 2 of your 19 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 - 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 1 of your 19 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
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 13 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 Relationship Review | 8 | 20% | 14 | 49 | 45% | 3 of 14 |
| The Policy Book | 7 | 18% | 14 | 87 | 83% | 3 of 14 |
| The Client Account | 4 | 11% | 14 | 80 | 77% | 3 of 14 |
| The Verification Desk | 4 | 11% | 14 | 85 | 83% | 2 of 14 |
| The Private Client File | 3 | 8% | 14 | 48 | 45% | 4 of 14 |
| The Client Engagement | 2 | 5% | 14 | 91 | 89% | 3 of 14 |
| The Onboarding Interview | 2 | 5% | 14 | 87 | — | — |
| The Securities Book | 2 | 5% | 14 | 53 | 50% | 3 of 14 |
| The Sponsorship File | 2 | 5% | 14 | 42 | 39% | 3 of 14 |
| The Betting Account | 1 | 3% | 14 | 67 | 63% | 2 of 14 |
| The Exchange Desk | 1 | 3% | 14 | 69 | 66% | 3 of 14 |
| The Goods Chain | 1 | 3% | 14 | 45 | 42% | 2 of 14 |
| The Incoming Payment | 1 | 3% | 14 | 69 | 65% | 3 of 14 |
Every method
All 19 methods that apply to this sector, and where each one is documented. Full citations are at amlbenchmark.com/coverage.
| Method | Case | Rate | Result |
|---|---|---|---|
| Art and Antiquities: self-dealing at auctionrarely trainedThe Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), made 9 June 2026 and in force 30 June… | The Private Client File | 45% | Missed |
| Estate Administration and Probaterarely trainedSolicitors Regulation Authority, thematic review of probate and estate administration (13 December 2024): 25 firms visited, three… | The Relationship Review | 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 |
| 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 |
| 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 | 50% | 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 |
| 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 |
| 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 |
| 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 Verification Desk | 83% | 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 |
| 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 | 89% | Detected |
| Necrofinance: dead directors and zombie accountsrarely trainedICIJ Panama Papers investigation (2016) into Mossack Fonseca | The Policy Book | 83% | Detected |
| 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 Verification Desk | 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 |
| 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 | 89% | 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.