OFFENDER'S PLAYBOOK · 90–120 min · 1–6 players

The Fee Earner

Mandate to dissolution. The whole life of a structure.

A three-mission campaign inside a corporate law firm. Take a client from first mandate through incorporation, operation, an investigation shock, and finally the wind-down, and learn which control at which moment would have stopped it.

⚑ Educational simulation. Every fee-earner move is paired with the control, the filing and the investigative step that closes it.

Other games

Learning objectives

01Follow an illicit structure across its entire lifecycle: formation, operation, shock, closure
02Identify the gatekeeper control point at each stage and who owns it
03Recognise how firms dissolve and migrate structures once an investigation begins
04Draft the evidentiary requests that survive a document-retention purge

Standards mapping

FATF Recommendations and CPD credit

Learning objective	FATF
Follow an illicit structure across its entire lifecycle: formation, operation, shock, closure	R.24
Identify the gatekeeper control point at each stage and who owns it	R.22, R.23
Recognise how firms dissolve and migrate structures once an investigation begins	R.23, R.24
Draft the evidentiary requests that survive a document-retention purge	R.11, R.31

R.22 DNFBPs: customer due diligence. Mandate acceptance is the first control point of the campaign.
R.23 DNFBPs: other measures. Reporting duty is tested at each of the twelve control points.
R.24 Transparency and beneficial ownership of legal persons. Formation and migration are played across the full lifecycle.
R.11 Record keeping. The wind-down mission turns on retention and purge timing.
R.31 Powers of law enforcement and investigative authorities. Evidentiary requests must survive the purge.

Also covers: FATF Guidance for Legal Professionals (2019) · UNCAC art. 12

CPD credit rationale

2 structured hours (2 verifiable) — streams: Legal practice ethics, Tax administration, Financial investigation.

Hours are claimed against structured learning: facilitated play against a published set of learning objectives, decisions scored on a rubric, and a written debrief retained by the participant. Three missions with checkpoint debriefs give an assessor twelve named control points and the participant's own intervention plan.

Evidence retained: Campaign scoresheet; Twelve control-point notes; Seizure priority list.

Table setup · 1–6 players

Best with 3–4 (practice group)

1Solo study

Work the mandate solo; the scorecard splits revenue from exposure.

2Head-to-head

Fee earner versus risk partner on every escalation point.

3–4Case cell

S1–S4; no mandate step advances without the risk partner's sign-off or an explicit override.

5–6Full table

Add S5 and S6 for a retrospective inspection and a public-exposure round.

Seats at the table

S1Fee earnerRuns the mandate and books the hours.
S2Practice headOwns the client relationship and the revenue target.
S3Risk partnerOwns conflicts, escalation and the file's defensibility.
S4Client's finance directorApplies pressure and supplies incomplete documents.
S5Regulator / supervisory inspectorReviews the file two years later.
S6Investigative journalistPlays the reputational consequence of each decision.

Team rules

01One seat, one voice: a decision is only locked when the seat that owns it says so out loud.
02Every locked decision needs a one-sentence justification the seat would defend in a real file.
03Any player may call a 60-second 'case conference' once per round to force a table discussion.
04The facilitator (or the highest-scoring player of the previous round) keeps time and reads the outcome cards.
05Every override of the risk partner must be written down — the inspection round reads them back.

Rotation — Rotate the risk-partner seat each mandate; overrides feel different from the other chair.

How to play

1.Three missions, played in order: Mandate & Formation, Operating Years, Shock & Closure.
2.Each round: pick a role, read the intel cards you unlock, then commit to one action.
3.Every action scores on Concealment and Exposure and branches the next round.
4.Stop at each checkpoint and mark your own debrief before continuing.

Mission

1 / 3

Rounds played

Concealment

0 pts

Clues spent

Your seat

Can accept or refuse the mandate outright; signs the engagement letter.

Mission I · Mandate & Formation · approx. 35 min

The client walks in with €40m and a story

Konstantin Verhoeven arrives through an introducer. He wants a holding structure for €40m of 'accumulated family capital' from a resources trading business in a jurisdiction with a thin public record. Your firm has three weeks and a €180,000 fee on the table.

Round 1 · Client intakeRound 1 of 4

The client-acceptance form is on the screen. The introducer is a private bank you have worked with for a decade. The source-of-wealth narrative is two paragraphs long and cites a 2009 privatisation.

Intel · reveal costs one clue token

Commit one action

Debrief · discuss with your team

Q1.At which of the twelve control points would your jurisdiction actually intervene today?
Q2.Which document would you seize first once the wind-down begins?
Q3.What did the firm gain from each layer, measured against what it cost in exposure?