Main ML/TF typologies for
Investment Firms in 2024 -
Details
Cellule de Renseignement Financier (CRF)
Impersonation fraud
• Refers to client impersonation fraud, but also includes fake CEO
or president fraud attempts;
• Portfolio managers get contacted, usually by email but also
phone calls, by someone pretending to be the client and
requesting a transfer (either partial or total) to be made to an
account held abroad;
• Falsified documents are often attached to an email sent to the
portfolio manager to appear as legitimate.
Fictitious loans
• Involvement of one or several loans as the main source of funds
being provided for investment financing purposes;
• These loans might be contracted between:
❑ a company and his sole UBO;
❑ an individual and a foreign PEP;
❑ sister companies held by a sole UBO;
❑ parents and children.
• Purposes of such loan schemes often include tax evasion.
• When companies are involved, it often includes wholly-owned
offshore holding companies.
Use of forged documents
• Apart from impersonation fraud cases, falsified or forged
documents might used by a client to:
❑ legitimate the purpose of one or several transactions;
❑ legitimate the role of a specific counterparty that has
initiated one or several transactions towards the client.
• Most frequently falsified documents include to-be-paid invoices
to justify incoming fund transfers and pay slips.
Transactions with third-party accounts or transit
accounts
• The use of third-party transactions or transit accounts for money
laundering purposes can occur in situations such as:
❑ The refunneling of funds to one or several third-party
accounts for alleged purposes such as real estate
purchases;
Misuse of legal entities
Situations that could be indicative of a money laundering scheme
exploiting legal entities include:
❑ The use of complex multi-jurisdictional ownership
structures without a clear rationale;
❑ The use of front companies to cover up illicit activities;
❑ Unjustified consecutive changes in shareholding and/or
beneficial ownership.
❑ Fraudulent transactions made to third-party accounts;
❑ The use of transit accounts to funnel funds from
seemingly unrelated third-parties.
