AFC Thoughts

Navigating the Complex World of PEPs with the AFC Ecosystem

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Tookitaki
10 Mar 2024
4 min
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Politically Exposed Persons (PEPs) pose significant challenges to anti-money laundering (AML) efforts worldwide. Due to their influential positions and access to substantial resources, they are at a higher risk of engaging in corruption, money laundering, terrorist financing, and bribery. Identifying and monitoring the financial activities of PEPs is crucial for financial institutions to prevent misuse of the financial system.

PEPs include individuals who are or have been entrusted with prominent public functions, as well as their family members and close associates. The risk profile of PEPs is heightened because their position may be exploited to commit financial crimes, including moving illicit funds under the guise of legitimate transactions. For this reason, financial institutions and regulatory bodies emphasize the importance of diligent scrutiny and enhanced due diligence processes when dealing with PEPs.

Understanding PEPs and Their Risks

Definition of a Politically Exposed Person (PEP)

A Politically Exposed Person (PEP) is someone who has been recognized as having a prominent public position, or someone who is closely related to such individuals. This definition includes a wide range of roles, such as government officials, political party leaders, judicial figures, and military officers. The close family members and business associates of these individuals are also classified as PEPs due to their potential access to the power and influence of the primary individual.

The High-Risk Nature of PEPs

PEPs are considered high-risk for engaging in financial crimes due to their position and the influence that comes with it. Their access to vast amounts of money and the ability to move it across borders makes them potential targets for corruption, money laundering, and even terrorist financing. The risks are compounded because PEPs may leverage their status to bypass standard regulatory oversight, making their financial activities less transparent and more susceptible to illicit dealings.

Methods PEPs Use to Evade Detection

To avoid detection, PEPs often employ sophisticated methods that mask their involvement in financial transactions. One common strategy is to reassign the legal ownership of assets to trusted friends or family members, making it difficult to trace the assets back to the PEP. Additionally, PEPs frequently use intermediaries to conduct transactions on their behalf, creating a web of financial moves that are hard to follow. They might also set up complex corporate structures without a clear business purpose, further obscuring the money trail and complicating efforts to identify suspicious activities.

HOW FATF CLASSIFIES PEPs

Red Flags in PEP Transactions

In monitoring transactions involving Politically Exposed Persons (PEPs), there are several red flags that financial institutions and regulatory bodies look out for to identify potential illicit activities. These indicators help in the early detection of suspicious behavior that may be related to money laundering, corruption, or other financial crimes.

Frequent Use of Intermediaries

One significant red flag is the frequent use of intermediaries in transactions. When PEPs consistently involve third parties to carry out financial dealings, it can signal an attempt to mask the true origin or destination of funds. This practice makes it challenging to trace transactions back to the PEP, thereby increasing the risk of money laundering.

Complex Corporate Structures

Another red flag is the establishment of complex corporate structures that lack a clear or legitimate business purpose. These structures are often designed to confuse or obfuscate ownership and financial flows, making it difficult for regulators and financial institutions to understand the true nature of the business.

Frequent Changes in Asset Ownership 

Lastly, frequent changes in asset ownership, particularly to individuals or entities closely associated with the PEP, can indicate attempts to disguise the true ownership of assets or to launder money. These changes often lack legitimate economic rationale and are intended to complicate the tracking of funds.

Strategies to Mitigate PEP-Related Risks

Financial institutions face the critical task of mitigating risks associated with Politically Exposed Persons (PEPs), a challenge that demands sophisticated strategies and technologies. 

Network Analysis

One effective approach is through Network Analysis, which plays a crucial role in unraveling the complex ownership and transaction networks often used by PEPs to conceal illicit activities. By dissecting these intricate linkages between entities and associates, network analysis enables institutions to detect suspicious connections and patterns that might otherwise go unnoticed, enhancing the ability to identify potential risks early on.

Risk Modeling

Another pivotal strategy involves Risk Modeling, where advanced risk models are utilized to pinpoint deviations from normal transaction behavior. This process is vital for monitoring transactions over extended periods, allowing for the identification of anomalies that could indicate money laundering or other fraudulent activities. By analyzing behavior over 30, 60, 90 days, or even longer, risk models provide a nuanced understanding of transaction dynamics, making it easier to spot irregularities that merit further investigation.

Investigative Measures

When red flags are raised, either through network analysis or risk modeling, Investigative Measures come into play. Deeper investigation is triggered to explore the nature of these anomalies, with a focus on understanding the context and the parties involved. Alerts play a crucial role in this phase, serving as timely indicators of suspicious activities that require immediate attention. The agility and depth of these investigative measures are critical in ensuring that potential risks associated with PEPs are comprehensively addressed, safeguarding against the exploitation of financial systems for illicit purposes.

The Role of AFC Ecosystem in Combatting PEP-Related Risks

The Anti-Financial Crime (AFC) Ecosystem represents a groundbreaking approach in the fight against financial crimes, including those involving Politically Exposed Persons (PEPs). This ecosystem is a tech-enabled, invite-only community platform that facilitates a collaborative environment for financial crime experts from various sectors. By sharing insights and new methods or "typologies" of financial crime, the AFC Ecosystem empowers institutions to enhance their defenses against complex schemes, including those executed by PEPs, through collective knowledge and real-time scenario analysis.

Central to the AFC Ecosystem's effectiveness is its ability to aid in the detection and prevention of financial crimes by leveraging community-driven insights and sharing real-world scenarios. This collaborative approach ensures that members can access a vast repository of financial crime patterns, known as "typologies," which are instrumental in preparing for and preventing novel types of financial crime. By integrating these insights into their operations, financial institutions can significantly improve their risk coverage and update their defense mechanisms against the sophisticated methods used by PEPs to evade detection​​.

The importance of identifying and mitigating risks associated with Politically Exposed Persons (PEPs) cannot be overstated in the ongoing battle against financial crime. PEPs, by virtue of their positions, have the potential to exploit the financial system for illicit purposes, making vigilance and advanced detection strategies essential. Through collaborative efforts and the utilization of cutting-edge tools like the Anti-Financial Crime (AFC) Ecosystem, financial institutions can significantly enhance their capabilities in spotting and preventing the sophisticated schemes employed by PEPs.

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Our Thought Leadership Guides

AFC Thoughts
18 Jul 2024
4 min
read

Typology Tales July 2024: Account Takeover Surveillance

We are pleased to share the latest edition of "Typology Tales" for July 2024. This edition highlights the new typologies that our Anti-Financial Crime (AFC) community has carefully analysed and selected. Our community's collective efforts are crucial in staying ahead of evolving financial crime threats, and we are grateful for your continued participation and contributions.

AFC Community’s Role

Each month, our dedicated AFC community comes together to analyze and evaluate newly created typologies, selecting those that can significantly enhance the ecosystem's ability to prevent and combat financial crime. The typologies chosen for publication are those that offer the most promise in terms of effectiveness and applicability across various scenarios.

Key Highlights from July 2024 

These typologies have been meticulously curated to ensure they provide robust and actionable insights, ultimately helping to safeguard the financial ecosystem.

Theme of the Month: Account Takeover Fraud (ATO)

Theme of the month

Account takeover fraud (ATO) is a type of cybercrime where unauthorised people access a user's account and use it for harmful purposes. This dangerous activity has increased significantly in recent times, posing a growing threat to both individuals and organisations. 

In this edition...

In this edition of Typology Tales, we delve into two typologies that compliance professionals can incorporate into their transaction fraud monitoring systems to proactively prevent account takeover in real time.

Typology 1: Surge in Multi-Party Transactions in Sizeable Values

Typology-multiple counterparty

A pattern of multiple parties making high-value transactions with one entity in a short period of  time suggests possible account takeover fraud. This requires a strategic review of transaction behaviours.

How It Works

  • The typology monitors transactions involving a single customer who receives or transfers funds with multiple parties within a short time span.
  • To identify potential account takeover risks, the typology groups transactions by the unique identifiers of senders and receivers within a specified time frame. By tracking these identifiers over a defined period, it can determine how many different parties have transacted with a particular entity.

  • Simultaneously, the typology aggregates the transaction amounts linked to unique senders and receivers.

  • It flags any entity that engages in transactions with a large number of different parties and exceeds a cumulative transaction threshold. This signals potential account takeover risks due to unauthorised access and high-value transactions.

Typology 2: Monitoring High-Value Transactions Across Multiple Payment Modes

15 - 2024 July Edition TT Typology tales-1-1-1-1

Financial institutions may implement advanced monitoring to detect high-value transactions between senders and receivers through various modes, aiming to uncover potential account takeover fraud.

How It Works

  • To effectively oversee the flow of funds, the typology tracks and aggregates transaction amounts based on the mode of transfer.
  • Transaction amounts, including those made through cash or alternative payments, are further aggregated by the unique identifiers of the sender and receiver over a specific period.
  • Entities showing high-value transactions across multiple payment modes over specified time frames are potentially flagged as suspicious. This increased activity may indicate that an account has been compromised and is being used to funnel funds illegally.

From the Media: Account Takeover Attacks Overtake Ransomware as Leading Security Concern

Research by cybersecurity firm Abnormal Security highlights that account takeover (ATO) attacks have become a top concern for security leaders. The 2024 State of Cloud Account Takeover Attacks report reveals that 83% of organisations experienced at least one ATO incident in the past year. 

Over 75% of security leaders rank ATOs among the top four global cyber threats, with nearly 50% facing more than five incidents annually and around 20% encountering over ten incidents. ATOs are now considered more significant than other threats such as spear phishing and ransomware.

Read More

Unite in the Fight Against Financial Crime

Financial crime is a pervasive issue that requires a collective, centralised approach to intelligence gathering. That's why we have created the Anti-Financial Crime (AFC) Ecosystem, a network of experts who work together to share knowledge and develop strategies for combating financial crime.

If you are an AFC expert, we invite you to join our efforts and help us grow the AFC Ecosystem. And if you know any other AFC experts, please refer them to us so we can continue to expand and strengthen our network. Together, we can make a real difference in the fight against financial crime.

Typology Tales July 2024: Account Takeover Surveillance
AFC Thoughts
01 Jul 2024
3 min
read

Account Takeover Fraud: Monitoring Entities Incorporated Long Back

In the evolving landscape of financial crime, financial institutions need to intensify their scrutiny of transactions from entities with a long history of incorporation but sporadic or recent activity. This increased vigilance aims to detect and thwart potential account takeover fraud within savings accounts, ensuring the safety and integrity of financial systems.

Given below is a typology from Tookitaki's AFC Ecosystem. It details how to ensure your monitoring system triggers alerts transactions from entities with a long history of incorporation

Understanding the Typology

Setting Up Entity Historical Profiles

Financial institutions employ a function known as the "Incorporation Date of the Entity" to track and record the incorporation dates and transaction activities of entities. This function helps identify entities that have been established long ago but have shown recent or sudden transaction activities, which could be indicative of fraud.

Function Configuration and Data Aggregation

  • Aggregate Fields: The system aggregates data on 'sender incorporation date' and 'receiver incorporation date.'
  • Aggregate Function: Using the collect_set function, the system compiles a unique set of incorporation dates for each sender and receiver, providing a comprehensive historical perspective of each entity's transaction timeline.
  • Group By: Transactions are grouped by unique identifiers like 'sender_hashcode' and 'receiver_hashcode,' linking each entity’s transaction history to specific account profiles.

Monitoring and Anomaly Detection

The system continuously monitors the transaction activities of these entities, comparing current transactions against historical data. Entities that have shown no or minimal transaction activities for a significant period since their incorporation are closely watched. A sudden spike in transactions, especially those of significant volume or frequency, triggers an alert. This scrutiny is particularly heightened if the entity's previous activity has been minimal or non-existent for years.

Group 16190-1

Flagging and Review Process

Transactions involving long-dormant entities resuming activity are flagged as high-risk. These flagged transactions undergo a detailed review to ascertain the legitimacy of the activity and to rule out any potential account takeover or other fraudulent intentions.

Investigative Measures

For flagged transactions, financial institutions conduct thorough investigations involving:

  • Background Checks: Verifying the entity's background.
  • Transaction Legitimacy: Confirming the legitimacy of the transaction.
  • Entity Ownership: Ensuring the entity's ownership and operational status.

Preventative Actions and Customer Interaction

If fraudulent activity is confirmed, financial institutions take immediate steps to:

  • Block further transactions.
  • Secure the affected accounts.
  • Possibly reverse fraudulent transactions.
  • Contact entity representatives for further clarification and to ensure all parties are informed of the situation.

Compliance and Reporting Obligations

All suspicious activities are documented and reported in compliance with regulatory requirements. This ensures that the institution remains compliant with anti-fraud regulations and aids in broader efforts to combat financial crime.

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Enhancement of Monitoring Systems

Based on findings and trends observed from monitoring these entities, financial institutions continually refine their detection algorithms and update their monitoring systems to better identify and prevent potential fraud.

By closely monitoring the activities of entities incorporated long ago but recently active, banks can effectively spot unusual patterns that may indicate fraudulent activities, such as account takeovers. This proactive approach helps safeguard customer assets and maintain the integrity of the financial system.

Final Thoughts

Financial institutions must remain vigilant and proactive in monitoring and analyzing transaction activities, especially those involving historically dormant entities. This typology, sourced from Tookitaki's AFC Ecosystem, highlights the importance of advanced monitoring techniques in detecting potential fraud.

We encourage anti-financial crime professionals to join the AFC Ecosystem to access unique typologies and leverage community-driven insights for enhanced fraud detection and prevention. Together, we can strengthen our defenses against financial crime and protect the integrity of our financial systems.

Account Takeover Fraud: Monitoring Entities Incorporated Long Back
AFC Thoughts
22 May 2024
3 min
read

The Globalization of Fraud: The Rise of Transnational Scams

In an increasingly interconnected world, the borders that once confined criminal activities are rapidly dissolving, aided by the rise of digitalisation and the pervasive reach of online platforms. The stark reality we face today is a landscape where fraudsters exploit digital payment systems to target individuals across the globe, particularly in the Asia-Pacific region. Organised fraud syndicates are not just local threats; they operate on an international scale, executing sophisticated scams that often outpace current preventative measures.

Case Study: A Transnational Crackdown on Job Scams

On 20 March 2024, a significant breakthrough came when the Commercial Affairs Department (CAD) of the Singapore Police Force and the Bukit Aman Commercial Crime Investigation Department of the Royal Malaysia Police joined forces in Kuala Lumpur. This joint operation was the culmination of extensive cross-border investigative efforts aimed at dismantling a formidable job scam syndicate.

Between October 2023 and January 2024, this syndicate deceived over 3,000 individuals, accumulating illicit gains of approximately $45.7 million. These scams primarily targeted Singaporeans, promising lucrative job opportunities that required victims to make upfront payments or divulge sensitive information under the guise of securing employment. The rapid escalation of these scams prompted an intensive collaborative investigation, which eventually led to the arrest of five Malaysians involved in laundering the proceeds from these fraudulent activities.

This operation not only highlights the severity and reach of transnational scams but also underscores the urgent need for global cooperation and shared strategies to combat these crimes effectively.

Job Scam

The Imperative of a Collaborative Approach

As we witness a surge in transnational fraud, the isolation of financial institutions in their silos makes them particularly vulnerable. The complexity and rapid adaptation of fraud strategies require that defences be equally dynamic and interconnected.

Collective Intelligence and Shared Responsibility

To counteract the evolving menace of cross-border fraud effectively, a collaborative approach is indispensable. The AFC Ecosystem initiative represents a commitment to fostering industry-wide cooperation and information sharing. Through this collective intelligence, we aim to establish a robust defence mechanism that not only identifies but also anticipates fraudulent activities, ensuring safe and secure societies. This shared responsibility is vital in creating an impenetrable barrier against the sophisticated mechanisms of modern financial criminals.

Considering the Typology of the AFC Ecosystem

Drawing from the AFC Ecosystem's insights, let's delve into the typology of transnational job scams. This framework is instrumental in understanding how these frauds operate and what measures can be employed to thwart their attempts.

Detailed Analysis of the Typology

Transnational job scams represent a highly organized and rapidly proliferating threat that exploits the aspirations of job seekers worldwide. These scams are not just about deceit regarding employment opportunities but involve intricate financial manipulations that siphon funds across international borders.

Operational Mechanics

  • Initial Recruitment: The scam begins with contact through social media or other digital platforms, where victims are lured with high-return, low-effort job offers.
  • Deceptive Promises: The roles are advertised as lucrative yet simple enough to attract a wide demographic, from students to the unemployed.
  • Financial Prerequisites: Victims are persuaded to make upfront payments or provide personal information as a part of the onboarding process.
  • Expeditious Expansion: To maximize profits before any potential crackdown, these operations quickly scale and replicate across various regions.

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Granular Red Flags and Risk Indicators

To effectively monitor and prevent these scams, it is crucial to recognise the following detailed risk indicators:

  • Value: Transactions often involve small amounts that are usually perceived as low-risk by victims, making them less likely to raise immediate alarms.
  • Volume: A high frequency of transactions complicates tracking and analysis, as the sheer number of transactions can overwhelm standard monitoring systems.
  • Velocity: The rapid succession of payments, coupled with potential chargebacks or cancellations, creates a chaotic financial trail that is difficult to follow.
  • Channels: Scammers predominantly use digital payment platforms, online banking, and occasionally cryptocurrencies to maintain anonymity and complicate tracing.
  • Anonymity: There is often a mismatch between beneficiary details and the purported employer, signalling a red flag for transactions.
  • Recurrence: Victims are frequently solicited for multiple payments under various pretexts, each justified as necessary for job commencement or continuation.
  • High-risk Geos: Payments are directed to accounts in high-risk jurisdictions or to those that are otherwise unrelated or suspicious, lacking any logical connection to the job or employer.
  • Geographical Inconsistencies: The involved countries often have no direct connection to the alleged job or employer, exploiting the complexities of international law and jurisdictional boundaries.

Harnessing Collective Efforts for Enhanced Security

The fight against transnational fraud is not a battle that can be won in isolation. It requires the concerted efforts of financial institutions, regulatory bodies, law enforcement, and the public. By adopting the typology provided by the AFC Ecosystem and vigilantly monitoring the detailed risk indicators, we can forge a path towards a more secure and resilient financial environment. This collective approach is our best defense against the sophisticated and ever-evolving landscape of global fraud.

The Globalization of Fraud: The Rise of Transnational Scams