The control gap we probe
Relationship tenure is treated as reassurance. The longer the client has banked with you, the less likely anyone is to re-test the structure, refresh the mandate or ask who is actually giving instructions now.
Sector assessment
19 laundering methods apply to this sector. 11 are rarely covered in standard AML training. The sector assessment uses 13 cases.
Private wealth laundering sits inside apparently legitimate ownership, lending and estate structures, which are rarely retested once a relationship is established.
Relationship tenure is treated as reassurance. The longer the client has banked with you, the less likely anyone is to re-test the structure, refresh the mandate or ask who is actually giving instructions now.
Beneficial ownership expectations under FATF Recommendations 24 and 25, and the ownership-and-control questions that followed the post-2022 designations, fall on firms holding complex private structures before they fall on anyone else.
Private banks, wealth managers and the trustees and family offices around them are all relevant persons. A family office that only manages one family's assets is still carrying out relevant activity, and the trustee of an express trust carries obligations of its own independent of the bank holding the account.
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 Relationship Reviewwritten for your desk | 8 | 20% |
| The Policy Book | 7 | 18% |
| The Client Account | 4 | 11% |
| The Verification Desk | 4 | 11% |
| The Private Client File | 3 | 8% |
| The Client Engagement | 2 | 5% |
| The Onboarding Interview | 2 | 5% |
| The Securities Book | 2 | 5% |
| The Sponsorship File | 2 | 5% |
| The Betting Account | 1 | 3% |
| The Exchange Desk | 1 | 3% |
| The Goods Chain | 1 | 3% |
| The Incoming Payment | 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. 19 of the 19 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.
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.
Rather than holding a fake face up to the camera, the attacker bypasses the camera entirely: virtual-camera software injects a pre-rendered or real-time face-swapped video stream directly into the onboarding app, so the liveness check is validating a video file rather than a person.
Emulator and virtual-camera artefacts in the capture stream, device and app-integrity signals that contradict a genuine handset, repeated onboarding attempts from the same device fingerprint under different identities, and capture metadata inconsistent with the phone the customer claims to hold.
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.
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.
An object of unverifiable age is commissioned or acquired, given a provenance story, consigned through a trust and bought back by its own beneficial owner through competing bidders, converting funds into an auction settlement.
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.
Property is nominally lost to a creditor while beneficial ownership never changes, or is held through a dissolved foreign entity that remains the registered owner.
Repossession followed by continued occupation or management by the former owner, debt routed through a professional intermediary, and funds flowing back to the supposedly dispossessed party.
Watches, vehicles, gemstones and collectables convert cash into portable value that resells readily and carries no ownership registry, moving across borders as personal property.
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.
A policy is used as a store and cleaning mechanism: a large single premium is paid, the policy is surrendered early at a deliberate loss, and the proceeds leave as an insurer payment, which downstream institutions treat as inherently clean.
Single premium payments from third parties or unrelated jurisdictions, early surrender accepted at a material penalty, frequent changes of beneficiary, and cooling-off cancellations with refunds directed to a different account from the one that paid.
Fabricated debt is guaranteed, defaulted, sued upon in a compliant jurisdiction and settled by court order, so proceeds arrive as a judgment rather than a payment.
Large inbound settlements supported by foreign court orders. The control weakness is that court-ordered recoveries are assumed clean and rarely receive enhanced due diligence.
Company formation, nominee director, registered office and trustee services are supplied at scale, assembling the structures other typologies depend on.
Clusters of customers sharing a registered office, a formation agent or a nominee, incorporated in batches, and presenting near-identical onboarding documentation.
Assets pass through the administration of a deceased person's estate, where the party whose funds they were is beyond enquiry. Due diligence is performed on executors and beneficiaries; the deceased is not checked, and the estate's assets move through a firm's client account before distribution.
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.
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.
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.
Clubs, sponsorship and image rights provide a channel for funds with weak valuation discipline, cross-border payments and a reputational shield that discourages scrutiny.
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.
Criminal funds are placed offshore and then lent back to the launderer, so the money returns as borrowing, complete with a repayment schedule, an interest deduction and an apparently arm's-length lender.
Borrowing from an offshore entity with no lending business, security or guarantees provided by parties connected to the borrower, interest paid to a jurisdiction unrelated to the transaction, and loans that are never enforced when they fall into arrears.
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.
The Relationship Review carries 8 of the 19 typologies above and 20 per cent of your mark. Full debrief, no account, no card.
Start The Relationship ReviewRun the full Wealth 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.