The control gap we probe
Surveillance is calibrated to price and volume anomalies rather than to economic rationale. A client who reliably loses money on fees is not an alert in most systems, and is one of the clearest indicators there is.
Sector assessment
18 laundering methods apply to this sector. 10 are rarely covered in standard AML training. The sector assessment uses 12 cases.
Laundering in capital markets looks exactly like trading, because it is trading.
Surveillance is calibrated to price and volume anomalies rather than to economic rationale. A client who reliably loses money on fees is not an alert in most systems, and is one of the clearest indicators there is.
The Deutsche Bank mirror-trading settlements established that regulators will treat commercially pointless but genuine trades as a financial crime failure, penalised on both sides of the Atlantic.
Investment firms, brokers and fund managers are relevant persons. The distinction that matters internally is that market abuse surveillance and financial crime are separate obligations answering different questions, and a firm with a mature surveillance function often has neither the data nor the alerts to answer this one.
Not one case. Every case that exercises a typology on your list is part of your mark, weighted by how much of your exposure it carries. The weights are derived from the register rather than chosen, so adding a case re-derives them instead of leaving the old ones wrong.
| Case | Your typologies | Share of your mark |
|---|---|---|
| The Securities Bookwritten for your desk | 5 | 17% |
| The Policy Book | 6 | 24% |
| The Verification Desk | 4 | 14% |
| The Relationship Review | 3 | 10% |
| The Trade Corridor | 3 | 10% |
| The Client Account | 2 | 7% |
| The Betting Account | 1 | 3% |
| The Exchange Desk | 1 | 3% |
| The Onboarding Interview | 1 | 3% |
| The Private Client File | 1 | 3% |
| The Sponsorship File | 1 | 3% |
| The Victim Ledger | 1 | 3% |
£99one payment, 12 months, nothing renews
£750pilot, up to 25 people, invoiced
Drawn from the full register and filtered to this sector. Each entry states what the typology looks like inside your own systems, and names the source it came from. 18 of the 18 are currently exercised by an assessment case; the rest are documented here and not yet built into one.
Deceased individuals are recorded as directors, officers and shareholders, and accounts opened by the living are run on after death. There is no accomplice who can be pressured, because the nominal principal is dead.
An account in good standing whose signatory died in a jurisdiction the firm does not search, filings continuing for a director with no verifiable life, and mandates never refreshed because the account never triggered a review.
A company is dissolved or struck off the register yet continues to bank, invoice and transact, because registry status is checked at onboarding and never again.
An established account whose entity no longer exists at the registry. Detectable only by re-verifying incorporation status across the existing book, which is a batch job most firms have never run.
Layered holding structures across free-zone and offshore jurisdictions terminate in a corporate nominee, so the declared beneficial owner is asserted rather than evidenced.
A structure chart that never evidences control, a nominee shareholder defeating verification, and a customer who offers further documents instead of an answer.
Statements, identity documents and supporting evidence are generated rather than obtained, and are internally consistent in ways genuine documents are not.
Statements with no fees or charges across months, running balances consistent to the penny, logos at incorrect aspect ratio, institution codes in the wrong format, identity photographs internally inconsistent or inconsistent with stated age, third-party webcam plugins during liveness checks.
A person who does not exist is assembled from a mixture of real and fabricated data, passed through onboarding, allowed to build a credit and transaction history, and then used as durable laundering infrastructure rather than for a single fraud.
Thin-file customers who behave impeccably for months, clusters sharing partial attributes such as address, device or contact details, credit files that begin abruptly in adulthood, and accounts whose only real purpose emerges long after onboarding.
Cloned voice defeats the control the firm added to catch impersonation: the callback. Voice biometrics and telephone banking authentication are attacked with audio generated from publicly available recordings.
Voice authentication passing on a call whose channel or device signals are inconsistent with the customer, callbacks answered on newly registered numbers, and instructions confirmed by voice that the customer later disputes entirely.
Synthetic video and voice impersonate executives on a live call to authorise urgent transfers, defeating the callback and video-verification controls firms adopted precisely to stop email-based impersonation.
Multiple urgent same-day transfers to new beneficiaries authorised by one employee, outside normal approval patterns, following a confidential instruction the payer cannot corroborate internally.
An entity claims government ownership to attract the lighter due diligence applied to state bodies, sometimes trading on a name close to a genuine state-linked company.
Due diligence closed out on an assertion of state ownership, and transaction volumes exceeding the plausible revenue of the entity the name resembles.
Residence or citizenship is obtained through qualifying investment, converting funds of uncertain origin into a residency status that subsequently anchors banking relationships and asset holdings.
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.
A respondent bank provides correspondent services to further institutions, so the correspondent's real exposure is to a chain of downstream banks it has never assessed and whose customers it cannot see.
Payment volumes and corridors inconsistent with the respondent's own customer base, beneficiary and originator fields naming institutions that are not the respondent, and activity in currencies or jurisdictions outside the stated relationship.
Extortion payments received in bitcoin are converted rapidly into stablecoins or swapped through decentralised protocols, often within hours, before distribution to affiliates.
Victim-side: an urgent, unexplained payment to an exchange or a specialist incident-response intermediary. Insurer and IR-firm accounts are a concentration point.
Illegally sourced timber, minerals, fish, wildlife, waste or oil is commingled with legitimate product early in the supply chain, after which the two are indistinguishable and the proceeds enter the financial system as ordinary commodity trade.
Commodity trade finance where volumes exceed the licensed or certified capacity of the stated source, certification and permit documentation that cannot be reconciled to the shipment, and front companies with no operational footprint at origin.
Matched opposite trades in the same securities are placed through two branches by commonly controlled entities, converting currency and moving value while appearing to be ordinary market activity.
Customers whose trades consistently lose money on fees and spreads, identical baskets bought and sold across branches, and no economic rationale beyond currency conversion.
Subscribing for shares in a controlled vehicle is used as the payment mechanism for goods or obligations, with the security standing in for an invoice.
Subscription monies from investors with no investment profile, funds with no genuine strategy, and redemptions issued as cards or transfers in unrelated jurisdictions.
A campaign is funded by pre-arranged participants, run over several weeks and wound up, with the venture's failure removing any party with an interest in scrutinising it.
Platform settlements to a venture with no product history, funding concentrated among connected contributors, and a rapid orderly wind-up.
Improper payments are routed as consultancy fees, royalties, dividends or capital gains so the receipt reads as ordinary income.
Consultancy receipts from jurisdictions where the recipient holds influence, payments unconnected to any deliverable, and timing correlated with contract awards.
Ownership is diluted below control thresholds or transferred to non-designated relatives and managers after designation, leaving effective control unchanged.
Ownership changes closely following a designation date, incoming owners with no commercial history, and unchanged management across the restructuring.
Ageing tankers under opaque ownership carry sanctioned cargo, disabling or falsifying position reporting and conducting ship-to-ship transfers at sea so the cargo's origin is severed from its documentation.
Trade finance and insurance exposure to vessels with dark intervals during loading, attestations that cannot be reconciled with position history, charterers and shipowners incorporated shortly before the voyage, and repeated changes of flag and name.
The Securities Book carries 5 of the 18 typologies above and 17 per cent of your mark. Full debrief, no account, no card.
Start The Securities BookRun the full Capital Markets benchmark across up to 25 people for £750.
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One documented case each week. One decision. The answer and the source afterwards.