Glossary
116 terms, defined in plain English. Link to any of them directly with
#term anchors.
- # Acquirer
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The bank or payment firm that signs merchants up to accept cards and settles their sales through the card networks. Card networks hold acquirers responsible for what their merchants actually sell.
- # AML (anti-money laundering)
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The body of laws, regulations, and institutional controls aimed at detecting and preventing money laundering. AML rules require banks and other regulated businesses to identify customers, monitor transactions, and report suspicious activity to authorities.
- # Bank Secrecy Act (BSA)
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The 1970 US law that created modern financial recordkeeping and reporting duties, including the $10,000 currency transaction report. Most US AML rules, and FinCEN's authority, hang off the BSA.
- # Beneficial owner
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The real person who ultimately owns or controls an account, company, or asset, regardless of whose name is on the paperwork. Hiding the beneficial owner behind companies and nominees is the core move of most laundering structures.
- # BMPE (Black Market Peso Exchange)
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A trade-based system in which a peso broker buys a cartel's US cash at a discount, uses it to pay US exporters on behalf of Latin American importers, and delivers pesos to the cartel at home. Dollars never cross the border; goods do.
- # Casa de cambio
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A currency exchange house, especially in Latin America. Casas de cambio moved billions in cartel proceeds into US banks in the 2000s, the mechanism behind the Wachovia case.
- # Cash courier
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A person who physically carries or ships currency across a border for someone else. Couriers are often the most exposed part of a bulk cash smuggling chain.
- # CBI / RBI (citizenship or residence by investment)
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Government programmes, often called golden passports or golden visas, that grant citizenship (CBI) or residence rights (RBI) in return for a qualifying investment or payment. Most applicants are legitimate, but regulators warn that weak checks on the source of funds can let illicit wealth in.
- # CDD / EDD (customer due diligence / enhanced due diligence)
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CDD is the standard package of checks on a customer's identity, ownership, and expected activity. EDD is the deeper version applied to higher-risk customers (politically exposed persons, correspondent banks, cash-heavy businesses), involving source-of-funds and source-of-wealth questions.
- # Chain-hopping
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Swapping illicit crypto rapidly across blockchains (Bitcoin to Ethereum to Tron) through bridges and swap services so no single chain's analytics see the whole route. A signature move of North Korea's Lazarus Group.
- # Chargeback
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A reversal of a card payment that the cardholder's bank forces after the cardholder disputes it. If the merchant cannot repay it, the payment company that sponsored the merchant usually has to cover it, which gives payment firms a reason to watch for fraudulent or laundered sales.
- # Civil vs. criminal forfeiture
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Criminal forfeiture takes assets as part of convicting a person; civil forfeiture sues the asset itself, on the theory the property is tainted, without needing a conviction. Civil forfeiture is how the US recovered 1MDB mansions and art from owners it could not arrest.
- # CMIR (currency border report)
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The US report (FinCEN Form 105) required when more than US$10,000 in currency or monetary instruments physically crosses the border, in either direction. Carrying the cash is legal; failing to report it invites seizure.
- # CoinJoin
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A collaborative Bitcoin transaction format in which many users combine inputs and outputs so observers cannot match who paid whom. Wallets built around it (Wasabi, Samourai) drew enforcement over money transmitted for criminals.
- # Compliance monitor
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An independent expert a regulator or prosecutor requires a bank to hire for a set term to review its controls and report on progress. Monitors can find problems the bank missed, as happened at Standard Chartered in 2014.
- # Consent order
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A regulator's order that a firm agrees to without contesting the findings, usually requiring a payment and a set of fixes. New York's financial regulator and the US Office of the Comptroller of the Currency use consent orders in anti-money laundering cases.
- # Corporate criminal liability (Switzerland)
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Under Article 102 of the Swiss Criminal Code, a company can be punished itself for certain offences, including money laundering, if it did not take all the organisational steps that could reasonably be required to prevent them. It can be charged even when no individual is convicted. Swiss courts have fined Credit Suisse under this rule.
- # Correspondent banking
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The arrangement that lets a bank in one country hold accounts with a big international bank to reach currencies and payment systems it lacks. The correspondent sees its customer bank, not that bank's customers: the blind spot behind Danske Bank and similar scandals.
- # Cover payment
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A payment method in which the bank holding the customer relationship sends the money through a US or other clearing bank, while sending the payment details separately to the receiving bank. Details the clearing bank never sees cannot be screened against sanctions lists, which is why regulators pressed banks to share fuller payment information.
- # Cross-chain swap
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A service or protocol that exchanges one cryptocurrency for another on a different blockchain, for example ether for bitcoin, often without a customer account. Investigators can still follow the on-chain trail, but the speed and lack of an operator to serve with a freeze request make recovery harder.
- # CRS (Common Reporting Standard)
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The OECD system under which participating countries automatically exchange information about financial accounts held by foreign tax residents. Misstating tax residence, for example with documents from an investment-migration programme, can undermine it.
- # Crypto ATM
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A machine that lets a customer exchange cash or a card payment for cryptocurrency and send it to a wallet address. In the US, operators are money services businesses that must register with FinCEN, verify customers and report suspicious activity. Kiosks are often used to collect scam payments from victims.
- # CTR (Currency Transaction Report)
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The report a US financial institution must file with FinCEN for cash transactions over US$10,000 in a business day, aggregated per customer. CTRs are routine and the customer is aware of them, unlike suspicious activity reports.
- # Cuckoo smurfing
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A laundering method that hijacks an innocent customer's expected international transfer: criminal cash is deposited into the recipient's account locally, while the clean funds abroad are diverted to the criminal. Named for the cuckoo's habit of laying eggs in other birds' nests.
- # Darknet market
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An online marketplace reached through anonymizing software such as Tor, where vendors sell illegal goods and services and buyers usually pay in cryptocurrency. Many run their own wallets and mixing tools, so the market itself becomes a place to launder money.
- # De-risking
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When banks exit whole categories of customers (remitters, charities, entire countries' banks) rather than manage their AML risk. It pushes transactions into less-supervised channels, which is why regulators discourage it even while demanding tougher controls.
- # Disgorgement
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A payment that takes away a gain an organisation made from wrongdoing, separate from any fine. In the Dutch ING and ABN AMRO settlements, prosecutors calculated it from money the banks saved by not spending what proper compliance would have cost.
- # DNFBP (designated non-financial business or profession)
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The FATF category of non-bank sectors that should apply anti-money-laundering duties in certain situations: casinos, real estate agents, dealers in precious metals and stones, lawyers, notaries and other legal professionals, accountants, and trust and company service providers.
- # DPA (deferred prosecution agreement)
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A deal in which prosecutors file charges but suspend them while the company pays penalties and reforms under supervision, with dismissal if it complies. HSBC's 2012 resolution was a DPA; critics call DPAs the price of 'too big to jail.'
- # Egmont Group
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The global network of financial intelligence units (170+ members) through which FIUs exchange information across borders. Often the fastest legal channel for following money internationally.
- # Embassy banking
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Accounts held for foreign governments, embassies and diplomatic staff. In the Riggs case, US Senate staff found that many such accounts were used like private banking accounts by senior officials and their families, which made them a high money laundering risk.
- # Exchanger (digital currency)
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A third-party business that swaps a digital currency or payment token for ordinary money, and back again. Services that will not take deposits or pay out directly often rely on exchangers, which can be unlicensed and lightly supervised, to handle the on-ramp and off-ramp.
- # Express trust
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A legal arrangement, created on purpose, in which a settlor gives assets to a trustee to hold and manage for the benefit of beneficiaries. Trusts are lawful and common, but because legal title sits with the trustee, anti-money laundering rules ask for accurate records of who the settlor, trustee and beneficiaries are.
- # FATF (Financial Action Task Force)
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The intergovernmental body, founded at the 1989 G7 summit, that sets global AML standards (the 40 Recommendations) and grades countries against them. Its three-stage model of laundering and its grey and black lists shape law worldwide.
- # Fei ch'ien (flying money)
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The Chinese informal value-transfer tradition, dating to the Tang dynasty: a claim payable in another city, so value 'flies' without silver moving. Its modern descendants include the underground banking networks that match cartel cash with Chinese capital flight.
- # FIU (financial intelligence unit)
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The national agency that receives and analyzes suspicious-transaction and cash reports: FinCEN in the US, FINTRAC in Canada, AUSTRAC in Australia, the NCA's UKFIU in Britain. FIUs turn millions of filings into intelligence packages for investigators.
- # Free trade zone (FTZ)
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A designated area, often at a port or airport, where goods enter without the import duties and many of the customs formalities that apply elsewhere in the country. Also called free zones, export processing zones or special economic zones. Most are legitimate, but weakly supervised ones can add cover to trade-based laundering.
- # Freeport
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A high-security, tax-advantaged storage zone (typically near an airport) where art and valuables can be held and traded without entering any country's customs territory. Assets can change hands inside a freeport with minimal public record.
- # Front company
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A business with genuine operations used as cover for illicit funds: a restaurant or car wash whose books mix dirty cash into real revenue. Unlike a shell, a front actually trades; that is what makes its numbers hard to disprove.
- # Funnel account
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An account that collects cash deposits in many cities and is drained from somewhere else, moving value across a country without wires. FinCEN's 2014 advisory flagged funnel accounts as a cartel staple.
- # Gatekeeper
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A professional such as a lawyer, accountant, adviser or company service provider whose work gives clients access to the financial system. Regulators say gatekeepers are well placed to spot misuse, and their involvement can lend a transaction an appearance of legitimacy.
- # Grey list / black list
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FATF's pressure lists. The grey list ('jurisdictions under increased monitoring') names countries fixing strategic AML deficiencies under a plan; the black list ('call for action'), Iran, North Korea, and Myanmar as of August 2026, triggers enhanced precautions worldwide.
- # GTO (Geographic Targeting Order)
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A FinCEN order imposing extra reporting in specific places for a limited time. The best-known GTOs required title insurers to identify buyers behind all-cash residential purchases from 2016 until February 2026, when a nationwide reporting rule replaced them.
- # Guarantee marketplace
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An online marketplace, often run through Telegram, where sellers offer services to scam and fraud operations and the platform holds the buyer's payment in escrow until the service is delivered. US authorities say some of these marketplaces sell laundering services and have processed billions of dollars' worth of digital assets.
- # Hawala / hawaladar
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An informal value-transfer system, centuries old, in which a broker (hawaladar) in one country takes cash and a counterpart in another pays it out, with the brokers settling between themselves later. Overwhelmingly used for legitimate remittances; abused because value moves without a transaction record.
- # IDM (intelligent deposit machine)
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A type of ATM that counts cash deposited into an account and credits it instantly, so the money can be moved on at once. In the Commonwealth Bank case, the Federal Court recorded that the money laundering risk of IDMs was high because cash could be deposited anonymously at hundreds of locations with no daily limit.
- # IFTI (international funds transfer instruction)
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In Australia, the instruction to move money into or out of the country, which banks must report to AUSTRAC within a set time. IFTI reports let the financial intelligence unit and police follow offshore money flows, so unreported or late IFTIs leave investigators blind.
- # Image rights
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The commercial right to use an athlete's name, likeness and fame in advertising and merchandise. Payments for image rights are often sent to separate companies, which FATF noted can be misused to disguise salary, pay agents or move money.
- # Immobilisation (of bearer shares)
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A control that requires bearer share certificates to be held by a regulated financial institution or professional intermediary, which records who is entitled to them. It is one of the options FATF allows for existing bearer shares, alongside converting them to registered shares.
- # Integration
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The final stage: laundered money re-enters the economy as assets with their own paper trail (property, businesses, portfolios), producing income the owner can openly explain.
- # KYC (know your customer)
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The identification and verification work a financial institution does when taking on and maintaining a customer. KYC is the foundation the rest of AML sits on: monitoring only means something if the bank knows whose behaviour it is watching.
- # Layering
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The second stage: moving money through transactions, entities, currencies, and borders to bury the trail back to the crime. The goal is to make tracing cost more than the money is worth.
- # LCTR (Large Cash Transaction Report)
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Canada's equivalent of the CTR: a report to FINTRAC for cash transactions of C$10,000 or more, including amounts that reach the threshold within 24 hours combined. Casinos file them too, which is central to the Vancouver Model story.
- # Letter of credit
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A bank's written promise to pay an exporter once specified shipping documents are presented. Because banks check the documents, letters of credit get more scrutiny than open-account trade, but they cover a smaller share of trade.
- # Loan-back scheme
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Borrowing your own hidden money: an offshore entity the launderer secretly controls 'lends' funds back to them, creating a documented source of money and interest payments that look like business expenses.
- # Microcap
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A stock of a very small company, often priced at a few dollars or less, thinly traded and with little public information. Small groups can move its price, so regulators treat it as higher risk for fraud and laundering.
- # Mirror trading
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Matched securities trades (buying in one currency and office while a related party sells the same securities in another) that move money across borders with no transfer on any wire. Deutsche Bank's Moscow–London mirror trades moved about US$10 billion this way.
- # Mis-invoicing
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Declaring a price on trade paperwork that differs from the real value of the goods, either too high (over-invoicing) or too low (under-invoicing). The gap lets value move across a border without a matching payment.
- # Mixer / tumbler
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A service that pools many users' cryptocurrency and pays out equivalent amounts from the pool, breaking the on-chain link between coins in and coins out. Operators from Helix to ChipMixer have been prosecuted; the smart-contract mixer Tornado Cash was sanctioned in 2022 and delisted in 2025.
- # Money mule
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A person who receives and forwards illicit money through their own account, sometimes recruited knowingly, often deceived through job ads or romance scams. Mules give schemes real accounts with real identities attached.
- # MROS (Switzerland's reporting office)
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The Money Laundering Reporting Office Switzerland, the country's financial intelligence unit. Swiss financial firms must send it a report when they know or have reasonable grounds to suspect that assets come from crime. FINMA criticised Credit Suisse in 2021 for reporting a Mozambique-linked payment only in 2019.
- # MSB (money services business)
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A non-bank business that transmits money, cashes cheques, or exchanges currency: remitters, currency exchanges, some crypto businesses. MSBs must register and report in most jurisdictions, and weak or complicit ones are classic placement channels.
- # Multisignature (multisig) wallet
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A crypto wallet that needs approvals from several separate key holders before it will send funds. It limits the damage if one person's device is compromised, but only if every signer can see and check what they are really approving.
- # Nested exchange
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A crypto service that operates through accounts on a legitimate exchange rather than its own infrastructure, hiding its customers inside the host's traffic. The crypto equivalent of nested correspondent accounts.
- # Nesting (nested accounts)
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When a third bank or service quietly uses another institution's correspondent account, riding inside its access. The top-level bank believes it is serving one customer while actually serving that customer's hidden customers.
- # NFT (non-fungible token)
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A unique digital token recorded on a blockchain that represents an item such as an image or collectible. Because every NFT is different, there is no standard price, which makes fair value hard to judge and price manipulation harder to spot.
- # Nominee
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A person or firm who appears as a company's director or shareholder on behalf of someone else, under private agreement. Nominees let the real owner stay off every public document.
- # Non-resident customer
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A person or company that banks in a country where it does not live or operate, often through a company registered somewhere else. Non-resident business is higher risk because the bank cannot easily verify who owns the customer or where its money comes from.
- # NPO (non-profit organisation)
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In FATF's definition, a legal entity or organisation that primarily raises or disburses funds for charitable, religious, cultural, educational, social or fraternal purposes, or for other good works. FATF Recommendation 8 applies only to organisations that fit this definition, and most of them are considered low risk.
- # OFAC (Office of Foreign Assets Control)
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The US Treasury office that administers and enforces economic sanctions, including the SDN list. Banks that clear US dollars must block or reject payments that break OFAC rules, wherever the customer is located.
- # Open account
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A way of settling a trade in which the exporter ships the goods and the importer pays later by ordinary bank transfer, with no bank guaranteeing the deal. Wolfsberg estimates, cited by FATF and the Egmont Group, put about 80% of world trade on open account, so banks often see the payment but not the shipping documents.
- # OTC desk / broker
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An over-the-counter trading service that converts large amounts between crypto and cash privately, outside exchange order books. Lightly regulated OTC brokers are a main off-ramp where laundered crypto becomes spendable money.
- # Payable-through account
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A correspondent account through which the respondent bank's own customers can write cheques or send payments directly. Because the host bank may never see those customers, US rules require extra due diligence on these accounts.
- # Peel chain
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Moving a large crypto balance through a long series of addresses while 'peeling' small amounts off to exchanges at each hop, keeping every deposit below attention. The blockchain version of structuring.
- # PEP (politically exposed person)
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Someone holding or close to prominent public office: ministers, state-bank executives, their families and associates. Banks must apply enhanced due diligence to PEPs because public power plus opaque wealth is the classic corruption profile.
- # Pig butchering
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Long-con investment fraud in which scammers 'fatten' victims with fake trading gains before taking everything, an industry run from compounds in Southeast Asia, with proceeds laundered heavily through dollar stablecoins and guarantee marketplaces.
- # Placement
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The first stage of money laundering: getting crime proceeds, usually cash, into the financial system. It is the riskiest stage because it is where the money first meets a record.
- # PMLO (professional money laundering organization)
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A network that launders other people's criminal proceeds as a business, for a commission. FATF documented the model in 2018; Chinese underground banking networks serving cartels are the most consequential current example.
- # Predicate offence
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The underlying crime that generated the money: drug trafficking, fraud, corruption, tax evasion, human trafficking. Laundering is charged as a separate offence on top of the predicate, and in most regimes the predicate can have happened abroad.
- # Prepaid access
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Access to funds paid in advance that can be retrieved or transferred later through a card, code or electronic serial number. US rules treat providers and sellers of prepaid access as money services businesses, with exclusions for some low-value products.
- # Privacy coin
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A cryptocurrency whose ledger hides sender, receiver, and amount by design; Monero is the main example. Conversion into a privacy coin ends most on-chain tracing, which is why many exchanges have delisted them.
- # Private banking
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Banking services for wealthy clients, run through a personal relationship manager who can open accounts, arrange transfers and set up companies on the client's behalf. The US PATRIOT Act requires extra due diligence on private banking accounts held for foreign political figures.
- # Pump and dump
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A market manipulation scheme in which insiders raise the price of a cheap, thinly traded stock through promotion or orchestrated trading, then sell to outside buyers at the inflated price. The sale proceeds are fraud proceeds that then have to be moved and disguised.
- # Ransomware
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Malicious software that blocks access to a computer system or its data, often by encrypting it, so the attacker can demand a ransom to restore access. Many attackers also steal files and threaten to publish them. Extortion and computer fraud are predicate offences to money laundering.
- # Ransomware-as-a-service (RaaS)
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A business model in which developers sell or lend ransomware to others who have separately gained access to a victim's network, and take a share of any ransom paid. FinCEN says the DarkSide attack on Colonial Pipeline followed this model.
- # Remitter
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A business that transfers money for customers, often across borders, and usually must register with a financial regulator. Complicit remitters are the hub of cuckoo smurfing.
- # Respondent bank
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The bank that uses another bank's correspondent account to reach currencies or payment systems it does not have itself. The correspondent bank knows the respondent as its customer, but often does not know the respondent's own customers.
- # Round-tripping
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Sending money out of a country illicitly and bringing it back disguised as foreign investment or a foreign loan, often through treaty jurisdictions. The returning money enjoys a welcome mat (and sometimes tax benefits) instead of scrutiny.
- # SAR (Suspicious Activity Report)
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A confidential report a US institution files with FinCEN when activity looks suspicious, generally from $5,000 with suspicion (or at any amount for some conduct). Filing is secret; telling the customer is itself an offence.
- # SDN (Specially Designated National)
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A person or entity on OFAC's sanctions list whose property in the US or in US hands is blocked, and with whom US persons generally may not deal. Foreign firms that keep dealing with a designated party risk sanctions of their own.
- # Section 311 (special measure)
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The USA PATRIOT Act power that lets the US Treasury name a foreign institution or jurisdiction of primary money laundering concern and restrict US banks' dealings with it, including correspondent accounts. FinCEN used it against Huione Group in 2025.
- # Shelf company
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A company incorporated and left dormant ('on the shelf') so it can be sold later with an established registration date. The aged paperwork helps a new owner look like a long-running business.
- # Shell company
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A legally registered company with no real operations, staff, or premises, existing mainly to hold assets or accounts. Shells are legal to create; stacking them across jurisdictions to hide ownership is the standard layering structure.
- # SMR (suspicious matter report)
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In Australia, the report a bank must send to AUSTRAC within three business days of forming a suspicion on reasonable grounds that information it holds may be relevant to a crime, or that a customer is not who they claim to be. It is the Australian counterpart of the US SAR.
- # Smurfing
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Structuring done with a crew: many hired depositors ('smurfs') each placing small amounts across branches and accounts. The name comes from the swarm of small, interchangeable cartoon characters.
- # Stablecoin
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A cryptocurrency pegged to a fiat currency, usually the US dollar: Tether (USDT) above all. Speed, stable value, and a global broker network have made dollar stablecoins a dominant rail for laundering scam and sanctions proceeds.
- # STR (Suspicious Transaction Report)
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The Canadian (and international) counterpart of the SAR, filed with FINTRAC on reasonable grounds to suspect a transaction relates to money laundering or terrorist financing. STRs have no minimum dollar threshold.
- # Structuring
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Splitting cash transactions into amounts below a reporting threshold so no report is filed. A standalone crime in the US since 1986, regardless of where the money came from.
- # Successor liability
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The question of whether a company that takes over another in a merger inherits the criminal responsibility for the other company's past conduct. In the Credit Suisse cases, UBS argued that it does not, and Swiss courts sided with UBS in 2026 rulings that were still open to challenge.
- # TBML (trade-based money laundering)
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Moving value through trade paperwork (over- or under-invoicing, phantom shipments, misdescribed goods) so money crosses borders disguised as payment for commerce. Exploits the fact that customs and banks rarely check invoice prices against market value.
- # TCSP (trust and company service provider)
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A business that forms companies and trusts, supplies registered addresses, and often provides nominee directors. FATF treats TCSPs, along with lawyers, accountants and real estate agents, as gatekeepers that need anti-money-laundering controls.
- # Terrorist financing
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Raising, moving, storing or using funds to support terrorism. Unlike money laundering, the money can come from legal sources such as donations, and the aim is to fund violence rather than to hide the proceeds of a crime.
- # Third-party ownership (of players)
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An arrangement in which an outside investor, not a club, holds a share of a player's future transfer value. FATF's 2009 football report flagged these arrangements as opaque, and FIFA has banned them since 1 May 2015.
- # Trade Transparency Unit (TTU)
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An office that exchanges customs and trade data with a partner country so analysts can compare what a shipment was declared to be worth on each side of the border. US Homeland Security Investigations runs the US program, and the GAO reports its first partner unit was set up with Colombia in 2005.
- # Transaction laundering
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Processing card payments for a hidden business through another merchant's legitimate account, or through a fake storefront. The processor vets the front merchant while the real commerce rides underneath.
- # Transaction monitoring
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The ongoing review of customers' payments, usually by software that raises alerts when activity looks unusual for that customer, followed by staff who investigate each alert. Regulators fault banks when systems raise too few alerts, cover too few scenarios, or leave large backlogs of alerts unreviewed.
- # Transshipment
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Moving goods from one ship, plane or truck to another at an intermediate stop on the way to their final destination, often in a port or free trade zone. Routes with several unexplained transshipments are a recognised trade-based laundering red flag.
- # Travel rule
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The requirement that identifying information about sender and recipient 'travel' with a funds transfer, so the trail survives across institutions. FATF extended it to crypto transfers in 2019, forcing exchanges to pass customer data the way banks do.
- # TTR (threshold transaction report)
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In Australia, the report a bank must send to AUSTRAC within 10 business days when a customer deposits or withdraws physical cash of A$10,000 or more. Like the US CTR, it is routine and does not mean wrongdoing. Its value is that investigators can trace large cash movements back to people and accounts.
- # Unhosted wallet
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A crypto wallet the user controls directly, with no exchange or other third party holding the funds. Transfers to and from unhosted wallets can fall outside an exchange's identity checks, so regulators treat them as a risk factor.
- # UWO (unexplained wealth order)
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A court order, pioneered in the UK in 2018, compelling someone to explain how they lawfully acquired an asset; an unsatisfactory answer supports recovering the property. It shifts the practical burden onto the owner.
- # VASP (virtual asset service provider)
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FATF's term for crypto businesses (exchanges, custodians, some wallet providers) that fall under AML obligations. If a service touches customer crypto, regulators increasingly expect it to run KYC like a bank.
- # Vostro account
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An account a bank holds in its own currency for another bank, used to settle that bank's international payments. Because the holding bank sees only the other bank's flows, not its customers, these accounts need careful risk-based monitoring.
- # Wash trading
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Trading an asset with yourself through different accounts to fabricate volume or price. In laundering, a wash-traded 'sale' (of a security or an NFT) manufactures a plausible receipt for moving value.
- # Wwft (Dutch anti-money laundering act)
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The Dutch Money Laundering and Terrorist Financing (Prevention) Act, which requires banks and other businesses to check their customers, watch their transactions and report unusual transactions to the financial intelligence unit. Dutch prosecutors have used it against ING, ABN AMRO and Rabobank.