Securities and brokerage
How are securities and brokerage accounts used to launder money?
Securities firms can be used two ways. Criminals can move outside money through brokerage accounts, often held by offshore shell companies and nominees. Or the market itself can create the money: a manipulated penny stock, such as in a pump-and-dump, produces fraud proceeds that then need to be moved and disguised.
As of September 2026: The September 2014 EDNY indictment is a set of allegations, and the announcement states that defendants are presumed innocent; this page does not state how that case ended. The Canaccord order is a consent order from March 2026: Canaccord admitted the facts in it, and its undertaking, including a lookback of suspicious activity reports, was still in progress at that date.
How are securities and brokerage accounts used to launder money?
Stock markets are built to move value quickly. A person can turn cash into shares and shares into cash in a matter of days, in almost any currency, through firms in almost any country. That speed and openness is the point of a market. It is also why FATF, in its 2009 report on the securities sector, described the industry as unusual: it can be used to launder money that was obtained somewhere else, and it can also be the place where illicit money is made, through fraud in the securities markets themselves.
Those two roles are worth keeping apart.
In the first, the securities account is a pipe. Money from another crime is placed into a brokerage account, often held by an offshore company with a nominee at the head, and traded or moved on. The layering value is the account holder’s name: the broker’s identity checks land on the nominee or shell, not on the real owner.
In the second, the market is the source. A penny stock is manipulated, insiders sell to buyers who are drawn in by the rise, and the profit is fraud proceeds. Then the same group has to move that profit out and make it look legitimate. Trading itself is what creates the money, and moving it is the laundering.
A related technique, mirror trading, where paired trades in different currencies move money across borders, is covered on its own page.
How does laundering through securities work?
The public enforcement record shows several recurring steps.
- Owners set up a structure that keeps their name off the account. That usually means an offshore shell company with a nominee shareholder or director, and sometimes a broker set up in the same jurisdiction. The beneficial owner is hidden by design.
- The structure acquires shares in a small, thinly traded company. Because few people trade the stock, a small group can affect its price and its apparent volume.
- Trades are arranged to create the look of activity. These include matched trades, pre-arranged trades, and wash trades, in which there is no real change in ownership. Promotion may follow.
- The shares are sold to outside buyers at the higher price. This is where the proceeds are created.
- The proceeds leave the account, often to another country or to a third party. In the 2014 EDNY indictment, prosecutors alleged the group produced debit cards that could not be traced to the clients and let them move proceeds back into the United States.
- Where the stock trades in the open market, the sale looks like ordinary investing. The tax and reporting paperwork is aimed at the nominee, not the owner.
Why does it work?
Markets give a clean, legal explanation for a gain. A person who sold a stock at a profit has a plausible answer to “where did this money come from?” The broker’s confirmation and the market price are the paper trail. The sale itself may be entirely lawful even when the earlier trading that pushed the price up was not.
The second reason is that broker checks focus on the account holder. If the holder is an offshore company with a nominee director, the broker’s know-your-customer file can be complete and still not show the real owner. Regulators say brokers must understand the nature and purpose of a customer relationship and monitor it, but that duty depends on seeing beyond the paperwork.
The third is volume. A busy broker-dealer sees millions of trades. FinCEN’s Canaccord order describes reports that produced thousands or millions of line items a year, and a wash-sale report that ran to more than 50 pages a day and was called “too long” to review. Where monitoring does not keep up, suspicious patterns get lost in noise.
The fourth is jurisdiction. In the EDNY case, prosecutors alleged the defendants created brokerages in Belize and shell companies in Belize and Nevis so that trading took place under nominee names. Cross-border structures slow down regulators, who need foreign cooperation to identify owners.
Real cases: an offshore brokerage scheme and a US broker’s penalty
Two public records show the two sides of the technique: the scheme and the control that was supposed to catch it.
The first is the September 9, 2014 indictment in federal court in Brooklyn against six people and six companies. The charges included conspiracy to commit securities fraud, tax fraud, and money laundering. Prosecutors said that between January 2009 and September 2014 the group, presenting itself as financial professionals, ran three linked schemes: defrauding investors in US-listed companies by hiding the real owners and manipulating price and volume; helping US clients avoid IRS reporting; and laundering about $500 million for more than 100 US citizens and residents.
To do it, the indictment said, the group set up shell companies in Belize and Nevis with nominees at the helm, and three brokerage firms in Belize: Titan International Securities, Legacy Global Markets, and Unicorn International Securities. As an example, the prosecutors described the trading of Cannabis-Rx, Inc., a penny stock. It had not traded since July 2, 2013. On March 28, 2014 it traded 189,800 shares, and its price fell from $13.77 on March 27 to $0.50 on April 16, 2014. These are allegations. The press release states that defendants are presumed innocent, and this page does not report how the case ended.
The second is a control failure. On March 6, 2026, FinCEN announced an $80 million civil penalty against Canaccord Genuity LLC, a US broker-dealer and a leading market maker in low-priced over-the-counter stocks. Canaccord admitted the facts. FinCEN said the conduct ran from March 2018 through June 2024. It found the firm had willfully failed to maintain a program reasonably designed to detect and report suspicious activity, including securities fraud in stocks where the firm made the market.
The details are about how monitoring fails. FinCEN said that until late 2021 just four employees, all with other duties, were assigned more than 100 unique reports. For stretches from months to four years, the firm did not review its low-priced, low-volume, pump-and-dump, self-trading, and wash-sale reports at all. Some compliance staff falsified records to look as if they had reviewed surveillance reports; the firm later fired them. Based on a preliminary lookback, FinCEN said Canaccord failed to file at least 160 suspicious activity reports across dozens of over-the-counter securities, covering suspicious transactions that FinCEN estimated in the thousands. Of the $80 million, $5 million was suspended, and $20 million each was credited for payments to the SEC and FINRA, leaving $35 million to be paid to the Treasury.
Importantly, this order is about a firm’s compliance program. It does not find that Canaccord itself laundered money.
How does securities laundering get caught?
The front line is the broker-dealer’s own monitoring. US broker-dealers must run an anti-money-laundering program, know their customers, and monitor accounts to report suspicious transactions. FinCEN’s order lists the kinds of pattern that surveillance is meant to find: matched trades, pre-arranged trades, wash trades, deposit and almost immediate liquidation of securities, dominating the volume in a stock, and marking the close. The SEC’s March 2021 risk alert to broker-dealers on suspicious activity monitoring shows the regulator’s attention to this area.
Second, regulators examine the examiners. FINRA had cautioned Canaccord about its AML program in 2014, 2017, and 2018, and a 2016 FINRA exam looked at the firm’s trading in nearly 4,500 low-priced Pink Sheet securities and found its controls inadequate. The 2026 penalty followed years of warnings that were not fully acted on. Multiple agencies acted together: FinCEN, the SEC, and FINRA.
Third, prosecutors follow the ownership. In the Brooklyn case, the allegations rested on showing that nominees and shells were fronts for identifiable clients, which is the central task in any securities laundering case. Undercover work and cooperation between agencies, including the SEC, were part of it.
Fourth, the cross-border side is a matter of information sharing. FATF’s typology work on the securities sector exists to help supervisors and firms recognize these patterns across borders. More on the general toolset is at how detection works.
Frequently asked questions
What is a pump-and-dump, and why is it a laundering issue?
In a pump-and-dump, insiders push up the price of a cheap, thinly traded stock, then sell to buyers drawn in by the rise. The sale proceeds are fraud proceeds. Moving them out through nominee accounts, offshore brokers, or other channels is the laundering step. Regulators treat both parts as connected.
What is a wash trade?
FinCEN's Canaccord order defines wash sales as trading with no change in beneficial ownership that is meant to create a false appearance of trading. It is prohibited under US securities law. For a stock manipulator it creates the look of volume; for a monitor, it is a warning sign.
Why do regulators worry about microcap stocks in particular?
Low-priced, thinly traded stocks have little public information and few buyers, so a small group can move the price. FINRA examiners flagged red flags in Canaccord's trading in such stocks, including matched trades, prearranged trades, wash trades, and deposit and near-immediate liquidation of securities.
Does a fine against a broker mean the firm laundered money?
Not necessarily. The FinCEN order against Canaccord was for failing to run a reasonable anti-money-laundering program and to report suspicious activity. It found the firm's platform could be used by others engaged in securities fraud; it did not say the firm itself laundered money.
Cases that used this technique
- Deutsche Bank Mirror Trades · Deutsche Bank's Moscow and London desks ran matching stock trades that turned rubles into dollars offshore, moving about US$10 billion out of Russia and drawing fines from New York and London in 2017.
Related techniques
- Mirror trading · Two matched securities trades in different currencies and offices, placed by connected parties, work as a hidden currency swap that moves money out of a country with no transfer to flag.
- Shell companies and nominees · Companies with no real operations hold accounts and assets while nominee directors and stacked ownership across jurisdictions hide the true beneficial owner.
- Insurance products · Cash-value life policies and annuities can turn unexplained money into an insurer's cheque, which looks like an ordinary maturity, loan, or surrender payout.
- Professional enablers · Lawyers, accountants, company formation agents, and real estate professionals whose ordinary services, knowingly or not, give illicit money a respectable paper trail.
Glossary
Sources
- Money Laundering and Terrorist Financing in the Securities Sector (FATF, October 2009).
- Six Corporate Executives And Six Corporate Entities Indicted For Orchestrating A $500 Million Offshore Asset Protection, Securities Fraud, And Money Laundering Scheme (US Attorney's Office, Eastern District of New York, September 9, 2014).
- Consent Order Imposing Civil Money Penalty, Canaccord Genuity LLC, Number 2026-01 (FinCEN, March 2026).
- FinCEN Assesses Historic $80 Million Penalty Against Canaccord Genuity LLC (FinCEN, March 6, 2026).
- Compliance Issues Related to Suspicious Activity Monitoring and Reporting at Broker-Dealers (Risk Alert) (US Securities and Exchange Commission, March 29, 2021).