All sectors

Sector assessment

Wealth and Private Banking

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.

Start The Relationship Review — 8 minNo account required · Full debrief at the end
Typologies for you
19
Assessed
19
Rarely trained
11
Aimed at
MLRO, Head of Client Due Diligence, Reputational Risk

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.

Supervisory context

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.

Who this is for

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.

The Wealth Assessment

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.

Cases in your assessment
13
Time to sit all of them
102 min
Typologies covered
19
Left uncovered
0
CaseYour typologiesShare of your mark
The Relationship Reviewwritten for your desk820%
The Policy Book718%
The Client Account411%
The Verification Desk411%
The Private Client File38%
The Client Engagement25%
The Onboarding Interview25%
The Securities Book25%
The Sponsorship File25%
The Betting Account13%
The Exchange Desk13%
The Goods Chain13%
The Incoming Payment13%

What you get for the price

£99one payment, 12 months, nothing renews

  • All 13 cases in your sector assessment, about 102 minutes, plus every other case on the site
  • Your mark for the Wealth Assessment, and a full debrief on every case naming each finding and its source
  • A certificate recording exact CPD hours, publicly verifiable
  • Re-sit any case as often as you like for 12 months

£750pilot, up to 25 people, invoiced

  • Your whole team sits the Wealth Assessment, not a single case
  • A gap report naming which of your 19 typologies the team detected and which they missed, with detection rates
  • Every participant gets their own full debrief
  • Deducted from a licence if you take one within 90 days
See an example gap report for Wealth

No VAT is charged. Team licences and seat counts.

The 19 typologies that apply to this sector

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.

Corporate and identity7

Necrofinance: dead directors and zombie accountsRarely covered in training

In the assessment

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.

What the analyst sees

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.

Beneficial Ownership Obfuscation

In the assessment

Layered holding structures across free-zone and offshore jurisdictions terminate in a corporate nominee, so the declared beneficial owner is asserted rather than evidenced.

What the analyst sees

A structure chart that never evidences control, a nominee shareholder defeating verification, and a customer who offers further documents instead of an answer.

Synthetic and AI-Generated Onboarding DocumentsRarely covered in training

In the assessment

Statements, identity documents and supporting evidence are generated rather than obtained, and are internally consistent in ways genuine documents are not.

What the analyst sees

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.

Biometric Injection and Liveness BypassRarely covered in training

In the assessment

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.

What the analyst sees

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.

Synthetic Voice Against Telephone and Callback ControlsRarely covered in training

In the assessment

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.

What the analyst sees

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.

Deepfake-Enabled Payment Instruction FraudRarely covered in training

In the assessment

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.

What the analyst sees

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.

Investment Migration and Residence Schemes

In the assessment

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.

What the analyst sees

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.

Assets and stores of value4

Art and Antiquities: self-dealing at auctionRarely covered in training

In the assessment

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.

What the analyst sees

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.

Real Estate: engineered foreclosure and retained controlRarely covered in training

In the assessment

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.

What the analyst sees

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.

High-Value Portable Goods

In the assessment

Watches, vehicles, gemstones and collectables convert cash into portable value that resells readily and carries no ownership registry, moving across borders as personal property.

What the analyst sees

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.

Insurance Product MisuseRarely covered in training

In the assessment

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.

What the analyst sees

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.

Professional and market7

Engineered Litigation and Court-Ordered SettlementRarely covered in training

In the assessment

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.

What the analyst sees

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.

TCSPs and Professional Enablers

In the assessment

Company formation, nominee director, registered office and trustee services are supplied at scale, assembling the structures other typologies depend on.

What the analyst sees

Clusters of customers sharing a registered office, a formation agent or a nominee, incorporated in batches, and presenting near-identical onboarding documentation.

Estate Administration and ProbateRarely covered in training

In the assessment

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.

What the analyst sees

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.

Private Placements and Subscription-as-Payment

In the assessment

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.

What the analyst sees

Subscription monies from investors with no investment profile, funds with no genuine strategy, and redemptions issued as cards or transfers in unrelated jurisdictions.

Bribery Conduits and Consultancy Payments

In the assessment

Improper payments are routed as consultancy fees, royalties, dividends or capital gains so the receipt reads as ordinary income.

What the analyst sees

Consultancy receipts from jurisdictions where the recipient holds influence, payments unconnected to any deliverable, and timing correlated with contract awards.

Sport Ownership and Sponsorship

In the assessment

Clubs, sponsorship and image rights provide a channel for funds with weak valuation discipline, cross-border payments and a reputational shield that discourages scrutiny.

What the analyst sees

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.

Loan-Back ArrangementsRarely covered in training

In the assessment

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.

What the analyst sees

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.

Sanctions and state actors1

Sanctions-Evasion Ownership Restructuring

In the assessment

Ownership is diluted below control thresholds or transferred to non-designated relatives and managers after designation, leaving effective control unchanged.

What the analyst sees

Ownership changes closely following a designation date, incoming owners with no commercial history, and unchanged management across the restructuring.

Sit your own sector's case before you commit a team to it

The Relationship Review carries 8 of the 19 typologies above and 20 per cent of your mark. Full debrief, no account, no card.

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