VERITAS · CASE FILE · SHELL-ARCHITECTOFFENDER'S PLAYBOOK · 60–90 min · 1–6 playersUBOAN INVESTIGATOR'S GAMESHELLARCHITECTBuild the structure. Learn to break it.№105
← All games

OFFENDER'S PLAYBOOK · 60–90 min · 1–6 players

Shell Architect

Build the structure. Learn to break it.

Assume the role of a corporate formation agent. Build a shell company from scratch — jurisdiction, nominee director, registered agent, bank, layering vehicles, and see the audit signature every choice leaves for an investigator.

⚑ Educational simulation. You play the offender to see the moves; then flip to investigator to close them.
Other games

Learning objectives

  • 01Map every step in constructing an offshore corporate vehicle
  • 02Understand why offenders pick each jurisdiction, agent and bank
  • 03Identify the audit trail each choice leaves for an investigator

Standards mapping

FATF Recommendations and CPD credit

Learning objectiveFATF
Map every step in constructing an offshore corporate vehicleR.24
Understand why offenders pick each jurisdiction, agent and bankR.22, R.10, R.28
Identify the audit trail each choice leaves for an investigatorR.24, R.10
  • R.24 Transparency and beneficial ownership of legal persons. Every construction stage is scored for the ownership trace it leaves.
  • R.22 DNFBPs: customer due diligence. Agent and nominee choices are gatekeeper CDD failures seen from the other side.
  • R.10 Customer due diligence. Bank onboarding is the stage where the structure is most exposed.
  • R.28 Regulation and supervision of DNFBPs. Jurisdiction choice tracks supervisory intensity.

Also covers: FATF Concealment of Beneficial Ownership (2018) · EU 5AMLD

CPD credit rationale

1.5 structured hours (1.5 verifiable) — streams: Tax administration, AML/CFT compliance, Legal practice ethics.

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. Offender-side construction is followed by an investigator round, so the claim rests on the counter-move analysis, not on the construction itself.

Evidence retained: Exposure-score sheet; Investigator counter-move list per stage.

Table setup · 1–6 players

Best with 4 (two builders, two investigators)

1Solo study

Build all six stages, then run the analyst unwind yourself.

2Head-to-head

Builder versus analyst; the analyst scores one counter-move per stage.

3–4Case cell

S1–S4 build; the app plays the unwind after the final stage.

5–6Full table

Builders S1–S4 versus S5–S6, who may intervene after any two stages.

Seats at the table

  1. S1Formation agentPicks jurisdiction, vehicle and registered agent.
  2. S2Nominee coordinatorStaffs directors and signatories; manages the paper distance.
  3. S3Private bankerOpens the account and writes the source-of-funds story.
  4. S4Client (beneficial owner)Sets the objective, budget and appetite for exposure.
  5. S5FIU analystFlips the structure at the end of each stage and names the tell.
  6. S6Supervisor / registrarApplies the transparency rules that would close each choice.

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.
  • 05Ethics rule: every builder choice must be read together with its investigator counter-move before the next stage.

Rotation — Swap builders and investigators for the second structure — nobody leaves having played only one side.

How to play

  1. 1.Six construction stages. At each stage, choose one option.
  2. 2.Every choice shows: offender rationale, cost, exposure score and investigator counter-move.
  3. 3.Final stage: an FIU analyst tries to unwind your structure. Score = how many layers survived.
Stage 1 / 6 · JurisdictionCost €0 · Exposure 0/30

The move

Jurisdiction

Where will you form the vehicle? Each option has different formation speed, cost and disclosure.

Session extension · +70 minutes

Take the session to full length.

Three additional facilitated missions with their own debrief checkpoints. Run them straight after the online round to take this title to a 60–120 minute workshop. Every checkpoint is self-marking — tick what you can genuinely defend.

Formation is the easy part. Now keep it alive through filings, audits and a bank review.

Tasks

  1. 01Each year, choose one maintenance action and pay its cost in exposure.
  2. 02Survive the year-three bank periodic review.
  3. 03Record which maintenance action created the largest documentary trail.

Checkpoint · Mark the operating years.

Debrief · discuss with your team

  • Q1.Which single choice created the most investigator exposure?
  • Q2.Where do beneficial-ownership registers in your region close these options?