AFC Thoughts

The Different Types of Money Laundering Techniques Used in Thailand

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Tookitaki
19 Apr 2023
7 min
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Money laundering is a critical issue in Thailand, posing significant challenges to the country's financial stability, integrity, and reputation. As a major regional hub for trade, finance, and tourism, Thailand is particularly susceptible to money laundering activities, which often involve organized crime, drug trafficking, and other illicit activities.

Understanding the various money laundering techniques used in Thailand is crucial for financial institutions, regulators, and law enforcement agencies in their efforts to combat financial crime. By staying informed about the latest methods employed by criminals, these stakeholders can better develop and implement effective anti-money laundering (AML) measures, thereby safeguarding the integrity of the country's financial system and mitigating the risk of financial crime.

This article aims to provide an overview of the different types of money laundering techniques commonly used in Thailand. It aims to raise awareness about these methods and emphasize the importance of staying vigilant against financial crime. Additionally, this blog will introduce Tookitaki's Anti-Financial Crime (AFC) Ecosystem, an innovative solution that can help financial institutions in Thailand strengthen their AML programs and effectively combat money laundering activities.

Common Money Laundering Techniques in Thailand

Money laundering techniques in Thailand are varied and complex, evolving over time to keep up with the ever-changing financial landscape. Some common techniques include trade-based money laundering (TBML), cash smuggling, real estate transactions, shell companies and nominee structures, cryptocurrency and digital assets, and hawala and alternative remittance systems.

Trade-based money laundering (TBML)

Trade-based money laundering (TBML) is a prevalent technique in Thailand, involving the manipulation of trade transactions to move illicit funds across borders. Criminals exploit the complexity of international trade, using methods such as over- and under-invoicing, multiple invoicing, and misrepresentation of goods to disguise the origin and movement of their illicit proceeds.

Cash smuggling

Cash smuggling, also known as bulk cash smuggling, is a common method used by criminals to move large amounts of cash across borders undetected. This technique involves physically transporting cash, often through the use of cash couriers or hidden compartments in vehicles, to evade the scrutiny of customs and financial institutions.

Real estate transactions

Real estate transactions are often used as a means to launder money in Thailand. Criminals purchase property with illicit funds, effectively integrating these proceeds into the legitimate financial system. In some cases, criminals may use intermediaries or shell companies to conceal their identities and the true source of their funds.

Shell companies and nominee structures

Shell companies and nominee structures are popular methods used by money launderers in Thailand. These entities have no real business operations but are used to hold assets and facilitate transactions that obscure the true ownership of funds. Nominee directors and shareholders can be employed to further distance the actual beneficial owner from the company and its financial dealings.

Cryptocurrency and digital assets

As cryptocurrencies and digital assets become more widespread, these financial instruments have increasingly been exploited for money laundering purposes in Thailand. Criminals can use digital currencies to move and store funds anonymously, making it difficult for authorities to trace the origins and beneficiaries of transactions.

Hawala and alternative remittance systems

Hawala and alternative remittance systems are informal money transfer networks outside the traditional banking system. While these systems can provide essential financial services in some regions, they are also vulnerable to exploitation by money launderers. In Thailand, criminals may use hawala networks to transfer funds across borders without detection, taking advantage of these systems' lack of regulation and oversight.

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An Overview of Thailand's AML Regulatory Regime

Thailand's Anti-Money Laundering Office (AMLO) is the key agency responsible for enforcing anti-money laundering and counter-terrorism financing laws. The country's legal framework primarily consists of the Anti-Money Laundering Act B.E. 2542 (1999) (AMLA), which has been amended over time to address evolving money laundering practices.

The Financial Action Task Force (FATF) has reported that Thailand has made good progress in addressing technical compliance deficiencies, improving its ratings on recommendations 13, 16, 19, and 20 from Partially Compliant to Largely Compliant. However, there are ongoing investigations into Thai banks for anti-money laundering, as highlighted by the FinCEN Files, which revealed transactions covering combined amounts of $41.31 million in four Thai banks.

Challenges in Combating Money Laundering in Thailand

Evolving Money Laundering Techniques

Criminals constantly adapt and refine their money laundering techniques to avoid detection and stay ahead of law enforcement efforts. This makes it difficult for authorities to keep up with the latest methods and trends, and it requires continuous monitoring and updating of measures to combat money laundering activities effectively.

Regulatory and Legal Framework

While Thailand has made progress in addressing technical compliance deficiencies, the country's regulatory and legal framework needs to be continuously improved to comply with international standards. This includes issuing new regulations and guidelines with specific and complex requirements for reporting entities to comply with, ensuring strict law enforcement.

Cross-border and Regional Complexities

Thailand's geographical location in the heart of Southeast Asia presents challenges in combating money laundering. The country shares borders with several other nations, making it vulnerable to cross-border criminal activities. Transnational organized crime, including narcotics trafficking, is a significant source of money laundering in Thailand, and the country must collaborate with its neighbours to effectively tackle this issue.

Technological Advancements and Emerging Risks

As technology advances, new risks and opportunities for money laundering emerge. Digital currencies and online financial platforms can be exploited by criminals for illicit purposes, making it challenging for law enforcement agencies and financial institutions to detect and prevent money laundering activities. Authorities must adapt to these technological advancements, develop innovative solutions to address emerging risks and maintain the financial system's integrity.

Tookitaki's AFC Ecosystem: Addressing Money Laundering in Thailand

Tookitaki's Anti-Financial Crime (AFC) Ecosystem is a community-based platform that brings together financial institutions, regulatory bodies, and risk consultants to share information, best practices, and experiences in the fight against financial crime. At the heart of the AFC Ecosystem is the Typology Repository, a database of money laundering techniques and schemes continuously updated to encompass a broad range of typologies, from traditional methods to emerging trends.

A graphical representation of a typology within the Typology Repository is shown below. 

Typology-Deviations in Account Activity

Key Features and Benefits of Tookitaki's AFC Ecosystem

Tookitaki's AFC Ecosystem offers several key features and benefits that address the challenges in Thailand's financial crime landscape:

  • Comprehensive Typology Repository: The AFC Ecosystem's Typology Repository ensures that financial institutions have access to the latest money laundering techniques and schemes, enabling them to identify better and address risks.
  • Enhanced Detection Accuracy: The AFC Ecosystem helps financial institutions improve their detection accuracy and maintain robust AML programs by providing access to up-to-date typologies.
  • Reduction in False Alerts: The AFC Ecosystem's insights, combined with Tookitaki's innovative technology, minimize false positives and allow financial institutions to focus on high-risk cases, reducing operational burden.
  • Adaptive Learning: Federated machine learning enables the integration of Tookitaki's AMLS with the AFC Ecosystem, ensuring that AML programs remain adaptive and up-to-date with emerging trends and regulatory changes.
  • Streamlined Compliance Processes: The AFC Ecosystem supports the modernization of compliance processes, resulting in faster response times and better alignment with evolving regulations.
  • Improved Collaboration: The community-based approach fosters collaboration and knowledge sharing among financial institutions, regulatory bodies, and risk consultants, creating a cooperative environment in the fight against financial crime.

How Tookitaki's AFC Ecosystem Addresses the Challenges in Thailand's Financial Crime Landscape

Tookitaki's AFC Ecosystem is well-suited to address the challenges in Thailand's financial crime landscape, including evolving money laundering techniques, regulatory and legal framework changes, cross-border complexities, and emerging risks due to technological advancements.

  • Evolving Money Laundering Techniques: The AFC Ecosystem's Typology Repository keeps financial institutions informed about emerging money laundering techniques, enabling them to adapt their AML programs accordingly.
  • Cross-border and Regional Complexities: The community-based approach allows for knowledge sharing and collaboration between institutions in Thailand and those in other countries, fostering a more comprehensive understanding of cross-border and regional money laundering risks.
  • Technological Advancements and Emerging Risks: The integration of Tookitaki's AMLS with the AFC Ecosystem through federated machine learning ensures that AML programs remain adaptive and responsive to emerging risks and technological advancements.

In short, Tookitaki's AFC Ecosystem offers a powerful solution to the challenges faced by Thailand in the fight against money laundering. By fostering collaboration, providing access to up-to-date typologies, and leveraging innovative technology, the AFC Ecosystem empowers financial institutions to effectively detect, prevent, and combat money laundering and related criminal activities.

Empowering AML Programs: Why Financial Institutions in Thailand Should Explore Tookitaki's Offerings

In conclusion, staying informed about money laundering techniques is crucial for financial institutions in Thailand to combat financial crime effectively. As money laundering techniques evolve, financial institutions must adapt their AML programs to maintain compliance and protect their businesses from potential risks.

Tookitaki's AFC Ecosystem is a game-changer in the battle against money laundering in Thailand. By fostering collaboration, providing access to an up-to-date Typology Repository, and leveraging innovative technology, the AFC Ecosystem empowers financial institutions to effectively detect, prevent, and combat money laundering and related criminal activities. This innovative solution addresses the unique challenges faced by Thailand's financial crime landscape and helps institutions stay ahead of the curve.

Financial institutions in Thailand should consider exploring Tookitaki's offerings to strengthen their AML programs. By adopting Tookitaki's AFC Ecosystem and AMLS, institutions can benefit from enhanced detection accuracy, reduced false alerts, streamlined compliance processes, and improved collaboration in the fight against financial crime. By embracing Tookitaki's innovative approach, financial institutions can ensure they have the most advanced tools and knowledge at their disposal to effectively detect, prevent, and combat money laundering in Thailand.

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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.

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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