Reference
The complete VERITAS terminology — every key term across four levels, aggregated and linked back to source lessons.
Compiled by Dr. Collen Lediga, Ruhr-Universität Bochum · 252 entries
South African term designating entities, including estate agents, subject to customer due diligence and suspicious-transaction reporting obligations.
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A measure of how closely reported earnings are backed by actual operating cash flow, as opposed to accounting accruals.
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The OECD's requirement to characterise a related-party transaction by its actual substance and conduct, not merely its contractual label.
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An FIU institutional design placing the unit within public administration but outside police and prosecution services, as with South Africa's Financial Intelligence Centre.
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Breakdown of identity verification at the point of account registration or transaction, typically at commission-incentivised retail agents rather than at the operator's head office.
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Technically lawful arrangements exploiting gaps or mismatches against the law's evident purpose; civilly, not criminally, remediated.
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A predicate-offence model treating any criminal conduct, domestic or foreign, as capable of generating launderable proceeds.
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A policy network of financial regulators, including many African central banks, addressing financial inclusion and de-risking impacts.
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The EU Anti-Money Laundering Authority, established by Regulation (EU) 2024/1620, headquartered in Frankfurt, with the AML Package applying from 2027.
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The EU's directly applicable Anti-Money Laundering Regulation extending CDD obligations to high-value goods dealers and imposing an EU-wide EUR 10,000 cash payment cap.
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The requirement that related-party transactions be priced as if between independent parties dealing at market terms.
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A national body, mandated under EU law, with real-time cross-registry access to accelerate tracing and cooperation on confiscated and frozen assets.
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The requirement that an expert flag, rather than silently embed, every factual assumption underlying a finding.
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A commercial analytics vendor's proprietary mapping of address clusters to named real-world entities, probabilistic and not independently auditable in most cases.
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Legal constraints, under instruments such as POPIA or GDPR, requiring meaningful information and human review for automated decisions with significant effect on individuals.
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The civil standard of proof requiring only that a proposition be more likely true than not, applicable to non-conviction-based forfeiture.
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The natural person who ultimately owns or controls a customer or an asset (typically defined as ≥25% ownership or effective control).
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A probabilistic model combining eight financial-statement variables to flag elevated risk of earnings manipulation.
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The empirical regularity that leading digits in many natural datasets follow a predictable logarithmic distribution, deviations from which can flag fabrication.
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Base Erosion and Profit Shifting — OECD term for aggressive tax structures that shift profit to low-tax jurisdictions.
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Detection method based on gaps between reported exports from country A and reported imports into country B for the same trade flow.
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A graph measure identifying entities on the shortest path between otherwise unconnected clusters, often flagging professional enablers.
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The criminal standard of proof requiring the fact-finder to be satisfied to a near-certain degree, applicable to criminal laundering convictions.
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A cartel takes turns winning tenders across a series of procurements, only visible when award data is aggregated across time.
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Recognising all discretionary impairments and provisions in one depressed period, often at a change of leadership, to flatter future comparatives.
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Recognising revenue on goods sold but retained in the seller's possession at the customer's purported request.
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The combination of travel-pattern, customs-declaration and FIU data used to risk-score travellers for targeted physical search rather than random selection.
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The deliberate order in which layers of a corporate structure are formed, typically most opaque/upstream first, operating entity last.
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The physical cross-border movement of large cash sums, typically by courier, to move illicit proceeds beyond the reach of the originating jurisdiction's financial controls.
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An indirect audit method reconstructing plausible turnover from a business's physical inputs (space, stock, staff-hours) to test declared revenue.
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The corruption of AML/CFT institutions themselves such that they provide legitimating cover for, rather than genuine prevention of, illicit conduct.
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Crypto-Asset Reporting Framework, the OECD's 2022/23 automatic-exchange standard for crypto-asset transactions, first exchanges scheduled for 2027.
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The OECD Crypto-Asset Reporting Framework and its EU implementing directive, extending automatic tax-information exchange to crypto-asset transactions from 2026-2027.
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A mandatory report filed by an accountable institution under the FIC Act for cash transactions above a prescribed value, regardless of suspicion.
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The agent-mediated conversion between physical cash and electronic mobile money value that anchors the entire mobile money model.
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The documented sequence of possession and handling of evidence from seizure to court presentation.
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Converting value across multiple blockchains, often via privacy coins or bridges, to break traceability.
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A less reliable technique distinguishing a transaction's payment output from its change output returned to the sender.
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Shipping product to distributors ahead of genuine demand to recognise revenue prematurely.
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A defence argument that the expert has assumed a transaction is illicit rather than testing an innocent explanation.
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OUR/SHA/BEN codes determining which party absorbs correspondent fees, explaining amount variance across a payment chain.
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An in rem proceeding against property itself, on the civil standard of proof, independent of any criminal conviction, POCA Chapter 6.
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Non-conviction-based recovery proceedings whose founding affidavits provide a public record of the state's own transaction-chain reconstruction.
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The 22 November 2022 ruling striking down unrestricted public access to EU beneficial-ownership registers as disproportionate.
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A segregated bank account held by a law firm on behalf of clients, historically treated by banks as lower-risk than the firm's own commercial account.
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A non-custodial technique combining multiple users' transactions into one, obscuring which input funded which output.
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Mixing illicit cash with a legitimate business's genuine takings so the two streams become indistinguishable once banked.
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The OECD's automatic-exchange standard under which financial institutions report non-resident account data annually to the account-holder's residence state.
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The inference that all addresses spending inputs within a single transaction share common control, since each requires the same signer's private key.
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A quantified adjustment made to a comparable transaction or company to account for material differences from the tested transaction.
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Cross-examination defence technique — refusing to accept multi-part premises without addressing each part separately.
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A targeted ICRG visit conducted before delisting to verify that legislated reforms are actually being implemented in practice.
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A fraudulent advisory or facilitation invoice used to move a portion of contract value to a PEP-controlled entity as concealed bribery.
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The use of internationally reputable advisory or audit firm contracts to make large fee flows to intermediary entities appear presumptively legitimate.
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A bank in Country A that holds an account for a respondent bank in Country B, providing access to Country A's payment system.
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A correspondent bank's decision to terminate relationships with an entire category or region of respondents rather than manage individual client risk.
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Competitors submit deliberately uncompetitive or non-compliant bids to create the appearance of competition around a pre-arranged winner.
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The doctrine that privilege does not attach to communications made in furtherance of an ongoing or contemplated crime or fraud.
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A protocol locking an asset on one blockchain and minting a wrapped equivalent on another, creating a formal ledger discontinuity.
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Common Reporting Standard, automatic exchange of financial account info between tax authorities.
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Corporate Service Provider, professional firm that incorporates and administers companies for clients.
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The EU's mandatory disclosure regime for cross-border tax arrangements bearing specified hallmarks, requiring intermediary reporting.
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POPIA and GDPR principles requiring that only data necessary for a defined purpose be processed, constraining even domestic analytical use of customer data.
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The collective analysis of data contributed by multiple institutions or jurisdictions, requiring a clear legal basis and embedded proportionality safeguards under FATF guidance.
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The wholesale exit by a correspondent bank from an entire respondent-country market judged high-risk.
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A cross-border cash control model requiring travellers to proactively declare amounts above a threshold regardless of whether asked, producing a record for every above-threshold movement.
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Reporting driven by fear of regulatory sanction rather than genuine risk assessment, inflating volume while diluting evidentiary value.
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A graph measure counting an entity's direct connections, useful for identifying transactional hub accounts.
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The FATF plenary decision removing a jurisdiction from increased monitoring once its action plan is substantially and verifiably complete.
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A visual exhibit, such as a flow-of-funds diagram, that simplifies underlying schedules for a fact-finder without distorting them.
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Development, Enhancement, Maintenance, Protection and Exploitation of an intangible — the OECD's test for which entity in a group is entitled to the IP return.
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FATF's glossary list of offence types every jurisdiction must cover, through an all-crimes or schedule-based approach, as launderable predicates.
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Establishing a specific identified predicate offence and tracing property to it, typically via a prior or parallel conviction.
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The EU's consolidated asset-recovery and confiscation Directive, strengthening Asset Recovery Offices, third-party confiscation, and interim asset management across member states.
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The prosecution's duty to disclose material capable of assisting the defence, not only material it intends to rely on.
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A cross-border cash control model requiring travellers to state carried amounts only when directly questioned by customs, relying on officer-initiated interdiction.
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Wealth or income materially exceeding any lawful, declared source, used as an inferential marker of criminal origin.
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The FIU's finished analytical output, chronology, entity mapping, typology classification and identified gaps; provided to law enforcement or prosecutors.
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Dubai Multi Commodities Centre, a major gold trading and refining hub subject to sustained scrutiny over provenance due diligence adequacy.
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The requirement, in extradition and mutual legal assistance, that the conduct alleged be a crime in both the requesting and requested states.
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The structural gap between multi-year, sometimes multi-decade recovery timelines and the much shorter political attention span of the governments pursuing them.
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The expert's overriding obligation to assist the court impartially, superseding loyalty to the instructing party.
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Enhanced Due Diligence — heightened checks for higher-risk customers.
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The assessment of whether a country's AML/CFT system actually achieves real-world results, measured against eleven Immediate Outcomes.
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Global body of Financial Intelligence Units facilitating cross-border information exchange.
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The Egmont Group's secure FIU-to-FIU information-exchange platform.
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A more intensive post-evaluation reporting track for countries with significant technical compliance or effectiveness deficiencies, requiring regular progress reports to the FSRB plenary.
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The process of determining when records from different sources refer to the same real-world person or legal entity, using probabilistic or deterministic matching.
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Exchange of Information on Request; a treaty partner responds to a specific request about a named taxpayer, assessed via Global Forum peer review.
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The initial questioning of a witness by the party that called them, used to establish qualifications, methodology and findings.
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The convention linking every figure on a summary schedule back to a specific, numbered source document and page.
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The capacity to articulate, at least at a high level, why a model produced a given output, particularly where the output materially affects a customer.
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Entity-resolution errors that either wrongly combine distinct entities or wrongly separate a single entity into apparent duplicates.
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The operational cost trade-off between conservative thresholds generating high manual-review volume and tighter thresholds risking missed true positives.
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The Paris-based intergovernmental standard-setting body that issues and revises the 40 Recommendations on AML/CFT/CPF.
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The global AML/CFT technical standard against which countries are evaluated.
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FATF's public list of jurisdictions with strategic AML/CFT deficiencies under an agreed action plan, distinct from the more severe 'Call for Action' black list.
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Public FATF designation of a jurisdiction with strategic AML/CFT deficiencies, raising perceived correspondent risk; South Africa was listed 2023 and delisted 2025.
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The 11 effectiveness measures used in FATF Mutual Evaluations to assess whether an AML/CFT system produces real-world outcomes, rated High/Substantial/Moderate/Low.
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FATF Recommendations on beneficial ownership of legal persons (rev. March 2022) and legal arrangements (rev. February 2023).
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Requires enhanced due diligence, source-of-wealth/funds establishment and senior management approval for politically exposed persons.
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The FATF standard requiring jurisdictions to implement a declaration or disclosure regime for cross-border cash and bearer negotiable instrument movements above a threshold.
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A free-text SWIFT MT field used for additional context, often containing unintentionally revealing detail.
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The national body that receives, analyses and disseminates suspicious transaction reports and other financial intelligence, without itself prosecuting or arresting.
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Narrowed US Corporate Transparency Act reporting to foreign-formed entities registered in the US, exempting most domestic companies.
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An overly broad request lacking sufficient particularisation, commonly a ground for refusal or clarification demands under MLA law.
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Registering a vessel in a jurisdiction offering favourable regulatory and disclosure terms, often unrelated to the beneficial owner's residence.
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Following tracks the same asset through successive hands; tracing in the strict sense follows value into a substitute asset after exchange or conversion.
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Swiss legislation in force since 2016 enabling administrative freezing and restitution of assets of foreign politically exposed persons, including where the origin state cannot itself pursue confiscation.
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A bit-for-bit copy of digital media taken at the point of seizure and hashed to prove it has not been altered.
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An operating enterprise, often with genuine trade, used principally to give illicit cash a plausible declared source.
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An autonomous regional membership organisation, such as ESAAMLG, GABAC, GIABA or MENAFATF, that adopts the FATF standard and conducts mutual evaluations of its own members.
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Free Trade Zone; customs-privileged area typically outside standard customs oversight.
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The process of identifying which party to a transaction actually performs functions, bears risks, and controls risk-mitigation decisions.
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General anti-avoidance rule empowering a revenue authority to re-characterise or disregard a transaction lacking commercial substance.
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South African legislation introducing beneficial-ownership register requirements and closing technical gaps ahead of the 2023 grey-listing.
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A UK/US-convened, StAR-supported initiative producing principles for transparent, accountable disposition of confiscated stolen assets returned to states of origin.
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Global Anti-Base Erosion rules under OECD Pillar Two, imposing a 15% minimum effective tax rate on large MNE groups, in force from 2024.
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Geographic Targeting Order — a U.S. FinCEN instrument requiring UBO identification for high-value cash real-estate purchases in specified markets.
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An informal value-transfer network based on trust and settlement between brokers, leaving no traditional bank trail.
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Harmonized System code — the international commodity classification used in customs declarations.
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The analytical fallacy of treating shared use of common infrastructure (utilities, payment aggregators) as evidence of a substantive relationship.
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The IFRS standard requiring disclosure of related-party relationships, transactions and balances.
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The FATF working group responsible for reviewing jurisdictions with strategic deficiencies and recommending grey-list or black-list status.
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The data-quality process of reliably matching records referring to the same individual or entity across disparate datasets and registries.
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Illicit Financial Flows — cross-border money that is illegally earned, transferred or used.
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The IFRS consolidation standard, effective 2013, replacing voting-control tests with a broader power-and-variable-returns control test.
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One of FATF's 11 effectiveness measures, rated High/Substantial/Moderate/Low.
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Eleven defined effectiveness goals, spanning risk understanding, operational enforcement and preventive measures, against which mutual evaluations assess real-world performance.
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A cross-examination line probing fee arrangements and repeat instruction to suggest bias in an expert's conclusions.
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Establishing that property is proceeds of crime through a constellation of circumstantial markers, without proving a specific predicate offence.
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A statutory legal basis permitting reporting institutions to exchange customer or typology information that ordinary confidentiality or data-protection law would otherwise restrict.
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Property used to commit or facilitate an offence, forfeitable regardless of whether it embodies criminal value itself.
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The structured, tagged messaging standard replacing legacy SWIFT MT formats for customer credit transfers, with full cutover completed November 2025.
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A team of investigators/prosecutors from two or more states operating under a single agreement, sharing evidence directly without sequential mutual-assistance requests.
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The deliberate selection of jurisdictions offering the weakest current practical discoverability for a given fact pattern.
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FATF's formal name for the grey list, denoting countries with strategic AML/CFT deficiencies that have committed to a time-bound action plan.
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Disclosures under ISA 701 requiring auditors to describe the matters of most significance in the audit of the current period's financial statements.
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Know Your Customer's Customer, a correspondent's due diligence on a respondent bank's own downstream customer base.
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The public record of real-estate title, mortgages and encumbrances.
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The professional (often a lawyer or accountant) who designs the overall multi-jurisdictional structure of a layering scheme.
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The forensic process of decoding a hawaladar's compressed transaction notation to identify counterparties, balances and settlement events.
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A determination, such as whether conduct amounts to money laundering, that lies beyond the proper scope of expert testimony.
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Protection for confidential lawyer-client communications made for the purpose of legal advice, subject to the crime-fraud exception.
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A non-binding document from the settlor to the trustee expressing intended treatment of the trust — often the most probative single document.
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A tracing doctrine limiting a claim against a mixed account to its lowest balance between the tainting deposit and the claim date.
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Mutual Agreement Procedure — a treaty mechanism for resolving double taxation disputes between two states' competent authorities.
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The unsuccessful NCA UWO against Zamira Hajiyeva, defeated on appeal in 2020, which chilled subsequent UWO applications until later legislative reform.
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Mutual Evaluation Report; the FATF/FSRB assessment of a jurisdiction's AML/CFT regime.
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The EU's comprehensive crypto-asset market regulation, with CASP licensing provisions applicable from December 2024.
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Simultaneous matched buy/sell across jurisdictions and currencies enabling opaque cross-border value transfer.
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Service that pools crypto deposits and issues withdrawals whose linkage to the deposit is obscured.
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Mutual Legal Assistance Treaty, formal instrument for cross-border evidence gathering.
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A framework requiring independent validation, ongoing monitoring, documented inventory and accountable ownership for analytical models used in compliance.
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The FATF Recommendation 14 category covering both formal money transfer operators and informal value transfer networks like hawala.
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A return modality directing confiscated value to a specific, independently audited use rather than an undifferentiated treasury deposit.
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An account, often registered by or coerced from an unwitting individual, used to receive and rapidly disperse illicit funds across several transaction hops.
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A bilateral or multilateral instrument governing formal, central-authority-to-central-authority requests for evidence usable in criminal proceedings.
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A structured, evidence-based, whole-of-government exercise ranking a country's money-laundering and terrorist-financing risks to guide resource allocation.
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Non-conviction-based confiscation; civil, in rem, or unexplained-wealth proceedings.
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A downstream bank using another bank's correspondent access, hidden from the correspondent's view.
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A downstream bank uses another bank's correspondent access, hiding the true originator from the correspondent.
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A downstream respondent bank routes payments through an intermediate correspondent that presents itself as the ordering institution, hiding the true originating bank from the ultimate clearer.
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The periodic reconciliation of reciprocal obligations between two hawaladars, often via trade invoices, compensating bank transfers or bulk cash.
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A quantification technique comparing the increase in a subject's net assets over a period to known legitimate income.
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Registered director who acts on the undisclosed instructions of a principal.
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Confiscation of assets on a civil, balance-of-probabilities standard, without requiring a criminal conviction of a specific individual.
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The same correspondent account viewed from each bank's own books; 'our account with you' versus 'your account with us'.
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A professional or business category subject to AML customer due diligence and reporting obligations under a given regime, as comprehensively listed in EU Regulation (EU) 2024/1624.
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The primary international standard for supply-chain due diligence on minerals from conflict-affected and high-risk areas, including gold.
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The one-to-two-week in-country phase of a mutual evaluation during which assessors meet the FIU, supervisors, prosecutors, industry and civil society.
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Open-Source Intelligence — investigation using publicly available information.
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A property sale priced above fair market value to move illicit value into the formal property market disguised as a commercial transaction.
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A model's weakness in detecting genuinely novel schemes because it was trained only on previously identified and caught patterns.
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Account whose sole function is to receive and immediately forward funds, holding no meaningful balance.
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An account through which the respondent's clients transact directly, using the correspondent's payment infrastructure.
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A repeated pattern of spending a small amount while returning the bulk of value to a new self-controlled change address, common in laundering and ransomware payment flows.
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The UK's domestic beneficial-ownership disclosure regime for UK-incorporated companies, extended in equivalent form to overseas entities owning UK land.
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Politically Exposed Person, an individual entrusted with prominent public functions, and their close associates and family.
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Recognising revenue on a long-term contract in proportion to work performed or costs incurred to date.
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The underlying crime whose proceeds are being laundered.
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Technical methods such as secure multi-party computation, federated learning or homomorphic encryption enabling joint analysis without exposing raw underlying data.
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Property or economic advantage derived directly or indirectly from the commission of an offence.
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Systemic misuse of thresholds, single-source justifications or localisation requirements to steer major contracts toward a captured network.
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The CJEU's three-part analytical framework for assessing whether an interference with a fundamental right is lawful.
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A person with reserve powers over a trust — often to veto distributions or replace the trustee.
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Falsifying an artwork's ownership history to give looted, stolen or illicit cultural property an apparently legitimate paper trail.
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An expedited parallel request seeking to freeze or preserve assets pending the outcome of the substantive evidence request.
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FATF's most severe designation, reserved for a small number of jurisdictions with the most serious, unaddressed strategic deficiencies.
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A structured, ongoing collaboration embedding law enforcement, FIU and private-sector analysts on thematic financial-crime operations, exemplified by the UK's JMLIT.
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Qualified Domestic Minimum Top-up Tax — allows a low-tax jurisdiction to collect the Pillar Two top-up tax itself rather than ceding it to another jurisdiction.
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The period around shipment date over which a commodity's exchange-quoted price is averaged to set the settlement price.
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UK register, introduced by ECTEA 2022, requiring overseas entities owning UK land to disclose their beneficial owners to Companies House.
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A court order preventing dissipation of an identified asset pending the outcome of confiscation or criminal proceedings, typically obtainable ex parte.
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A whistleblower-protection design in which the employer must justify any adverse action against a report-linked employee, rather than the employee bearing the burden of proving retaliation.
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A supervisory approach under FATF R.26/IO.3 requiring higher-risk institutions to receive proportionately more intensive oversight than lower-risk ones.
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A risk-scoring approach using explicit, legible indicators (e.g. structuring patterns, PEP status) that can be individually explained and audited.
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Evidence-based adjustment of transaction-monitoring rule thresholds and logic using historical alert-disposition data, documented with rationale.
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The failure mode of generating more correctly flagged high-risk cases than an institution has resources to investigate, creating an accountability exposure.
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The criminalisation of the original perpetrator of a predicate offence for subsequently laundering the proceeds of that same offence.
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A domestically defined category of tax offence, typically threshold-based, that FATF's 2012 revision requires jurisdictions to treat as a laundering predicate.
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The person who creates a trust by transferring property to a trustee.
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Legal entity with no significant operations, used as a holding or transaction vehicle.
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A subcontracting entity that performs no genuine work, used to convert bribe payments or profit-skims into deductible business expense.
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A nominee director or shareholder who exercises no independent judgment and may be named on thousands of entities simultaneously.
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Fraudulently obtaining a replacement SIM card for a victim's number to seize control of accounts and authentication channels tied to it.
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Coordinated, parallel audits of the same taxpayer or group conducted independently by two or more revenue authorities on an agreed timetable.
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A presumptive commodity-pricing method benchmarking export prices to quoted exchange prices on the shipment date, used widely in Latin America and referenced by ATAF.
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Source of funds traces a specific transaction's origin; source of wealth explains the PEP's overall net-worth accumulation over time.
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A legal entity created to hold specific assets or liabilities, sometimes structured to avoid consolidation despite retained economic exposure.
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Tender specifications are drafted, before publication, narrowly enough that only a pre-selected supplier can comply.
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A single high-level flow-of-money diagram supplemented by exhibit-level detail on request.
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The unprompted transmission of information by one state's authority to a foreign counterpart, without a prior formal request.
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A crypto-asset pegged to a reference currency (typically USD), issued by a centralised entity capable of freezing specific addresses.
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Stolen Asset Recovery Initiative, joint World Bank / UNODC programme supporting asset recovery.
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Systemic manipulation of public institutions and procurement by private interests for illicit gain, documented in South Africa by the Zondo Commission.
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Suspicious Transaction / Activity Report filed with the national Financial Intelligence Unit.
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Automated payment routing without manual review, screened only against structured fields, not beneficial ownership.
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Breaking large cash sums into multiple deposits below reporting thresholds, often across several accounts or depositors, to avoid triggering mandatory reports.
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Breaking a cash deposit into amounts below the mandatory reporting threshold.
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The genuine governance-risk dilemma facing asset-holding states when the current government of the victim state includes figures linked to the original theft or has weak public financial management.
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The uneven timing and quality of travel-rule implementation across jurisdictions, complicating counterparty data exchange.
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A mandatory filing by an accountable institution flagging a transaction or activity inconsistent with expected customer behaviour or risk profile.
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The ATAF/OECD/UNDP programme seconding experienced auditors to work alongside domestic auditors on live international tax cases.
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Trade-Based Money Laundering, moving illicit value under cover of trade transactions.
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A DNFBP-category professional providing company formation, registered office, nominee director/shareholder and trust administration services.
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The assessment of whether a country's laws and regulations formally meet the requirements of each FATF Recommendation, rated on a four-point scale.
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The two distinct FATF assessment scales; whether laws match the standards on paper, versus whether the system actually works in practice.
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The OECD's maturity-model framework (2017, periodically updated) for effective tax-crime investigation and inter-agency cooperation.
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FATF's core technical standard, organised into seven thematic groups covering policy, criminalisation, preventive measures, transparency, institutions and cooperation.
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A widely cited statement of expert independence, disclosure of assumptions, and willingness to revise opinions on new evidence.
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Funding a subsidiary disproportionately with related-party debt rather than equity to maximise deductible interest.
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A regulatory design permitting minimal identification for low-value accounts and progressively fuller verification as balance or transaction limits rise.
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Transactional Net Margin Method, tests a tested party's net profit indicator against a range derived from comparable independent companies.
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The forensic-accounting and legal process of establishing the current location of specific assets derived from a predicate offence, to a standard sufficient for a court restraint application.
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Using mispriced or fictitious trade invoices between associated trading entities to transfer the net settlement value owed between hawaladars.
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FATF R.15 obligation requiring VASPs to collect, hold and transmit originator/beneficiary data for virtual-asset transfers above a threshold.
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A scoring methodology that prioritises incoming reports for analyst attention based on reliability, typology match and existing intelligence links.
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Ultimate Beneficial Owner — the natural person who ultimately owns or controls an entity.
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Encourages states to criminalise a significant, unexplained increase in a public official's assets relative to their lawful income.
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The article governing return of confiscated assets to the requesting state.
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United Nations Convention against Corruption chapter on asset recovery.
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A UK High Court order requiring a respondent to explain the lawful source of property exceeding GBP 50,000, on pain of presumed recoverability if unexplained.
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A sequence of individually small post-award change orders that cumulatively and improperly multiply contract value beyond re-tendering thresholds.
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Virtual Asset Service Provider — exchange, custodian, or other regulated crypto business subject to FATF Recommendation 15.
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The FATF's functional category covering exchanges, custodial wallet providers and certain DeFi front-ends performing exchange, transfer or custody services.
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The deliberate deletion or truncation of originator/beneficiary data from a payment message to defeat sanctions or AML screening.
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The intermediate analytical layer reconciling raw source documents into the summary schedules tendered at trial.
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The Judicial Commission of Inquiry into Allegations of State Capture, chaired by Raymond Zondo, whose final report parts were published through 2022 and whose evidentiary record documents SOE-level capture.
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