Peeling Back the Layers: How Layering Techniques are Used in Money Laundering (2023)

What is Layering in Money Laundering?

Layering is a term that is often used when talking about how criminals use it to prevent the detection ofmoney launderingactivities.

Layering refers to moving money from one account to another and from one banking and financial institution to add layers of legitimate owners and avoid detection of the actual source of the funds and make it harder for authorities to track the initial source of the money.

Layering is a financial crime.

1. Placement in Money Laundering

It is the first step when the criminals receive money from unlawful activities. Now they move the money into the legitimate business accounts of the partners-in-crime- the criminals and their family, friends, and associates.

Businesses such as casinos and gambling are used to funnel the funds.

The trick is to break down the large volumes into smaller transactions that won’t attract much attention as the criminals ensure that the transaction remains within the cash limit threshold.

In this way, they can avoid deposit alerts. The standard procedure adopted by the criminals is to move money from these companies and use fake invoices. In this way, the money ultimately is run through the legal system avoiding scrutiny.

Read More about Placement in Money Laundering

2. Layering in Money Laundering

Layering is the second stage of money laundering wherein illegally obtained funds are placed into the financial system and moved to other banks and financial institutions to distance them from the criminal source.

The purpose of layering in money laundering is tomake the detection of source of illegal money as difficult as possible.

It is called layering when money launderers buy other liquid investment instruments using the illegally placed funds. Such funds are then transferred to other forms such as negotiable instruments or used to purchase goods and services to make their detection nearly impossible.

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It is worthwhile to note over here that structuring and layering in the money laundering mean one and the same thing.

The layering stage of money laundering makes the entire process of detecting money laundering complex, and it’s essential that money laundering is detected at the early stage of layering.

3. Integration in Money Laundering

Integration is the third stage of money laundering. Here the illegitimate funds are integrated into the legitimate economy.

Money launderers buy real estate, stocks, securities, jewellery, precious metals, or other luxury goods to integrate their laundered money into the financial system.

When it comes toterrorist financing, the integration is accomplished by distributing funds to terrorists and terrorist organizations.

Peeling Back the Layers: How Layering Techniques are Used in Money Laundering (1)

What are the common layering techniques used in the money laundering?

Some of the common layering techniques used in money laundering are:

  • Using intermediaries for a complex financial transaction
  • Fund or wire transfers via electronic media
  • Offshore banks where AML compliance is on a lower side
  • Opening of shell companies to layer the transactions
  • Creation of Trusts to obscure the origin of illicit funds
  • Use of multiple bank accounts and multiple jurisdictions to further complicate the paper trail
  • Use of assets such as real estate and precious metals to hide the movement of money

Money Laundering is a global concern. It is estimated that 2-5 % of global GDP, which ranges between USD 800 billion to USD 2 trillion, is laundered every year.

Criminals try to hide the source of the illegal money used to fund criminal activities such as the trade of banned drugs, human trafficking, kidnapping, extortion, and even purchasing arms and ammunition for terrorism. So, they launder the illegally obtained money, try to run it through the legal, regulated financial system, and use layering to avoid detection.

Criminal activities are on the rise as the criminals are misusing the financial system, taking advantage of the loopholes, and becoming successful in money laundering. It’s essential to report any transactions or account discrepancies and prevent financial crimes.

AML – Anti-money laundering rules and regulations have been implemented to combat money laundering and terrorist activities. These laws require financial institutions and other regulated entities to follow stringentAML complianceprocesses such asKYC– Know Your Customer,CDD– Customer Due Diligence, EDD- Enhanced Due Diligence,UBO identification, etc.

Peeling Back the Layers: How Layering Techniques are Used in Money Laundering (2)

The rules enable the institutions to detect and deter criminals from misusing their organisations to launder money.

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Criminals are using the layering method to hide their black money, which means they keep moving the cash from one account to another and transferring it from one company’s account to another. Check ourinfographic onstages of money laundering.

By moving the money, it is transferred to several legit accounts, so during an investigation, the names of several account holders crop up, making it harder to locate the origin of the illegal money. It makes identifying the source of the funds difficult for the authorities.

Challenges in detecting and combating layering in money laundering

The layering stage in money laundering is arguably the most crucial for the launderers. Illicit funds come out of the dark and blend with legitimate instruments.

Launderers conclude these multiple transactions to confuse standard money laundering controls, which institutions primarily establish.

After separation from the original source, the crime proceeds enter into the financial system.

Th funds are dispersed and disguised to reduce the chances of suspicion or detection from law enforcement agencies.

These funds are fragmented into smaller transactions and often transferred overseas to keep the money moving internationally, preventing the authorities from tracking the movement easily.

The possibility of transferring money electronically makes it easier to move it across borders, making it more difficult for officials to track.

How to identify money laundering activities?

There are specific activities in which institutions can monitor and identify money laundering:

  • A huge volume of cash is deposited into different bank accounts.
  • Frequent international transfers.
  • Purchasing & reselling high-value goods such as art and jewellery.
  • Investing in real estate
  • Investing in legitimate companies and using shell companies to layer money – moving money from one account to another.
  • Making multiple transactions in different accounts and financial institutions.

What is structuring in money laundering?

Structuring, also known as layering, is the second stage of money laundering. Structuring is the act of splitting a large financial transaction into a series of smaller transactions to avoid the regulatory threshold prescribed by the AML authorities of the country.

As perUAE AML Laws, all cash transactions in precious metals and stones equal to or exceeding AED 55,000/- need to be reported to thegoAML portalmaintained by the FIU.

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In order to avoid this reporting threshold, criminals split their purchases of precious metals, stones, and jewellery items in such a way that they avoid thisDealers in Precious Metals and Stores Report (DPMSR)filing requirements.

Using AI based AML Software to identify layering in money laundering

There are ai powered RegTechAML Softwareand solutions available which utilise the power of machine learning and big data to detect layering techniques in money laundering. AML Software solutions make it easy to identifyred flagsin transactions and separate them for further escalation.

AML Compliance: The need of the hour

AML laws in UAErequirefinancial institutionsandDNFBPSto create a robust AML compliance network and identify money laundering activities to prevent them with timely action.

Banks should adopt a proactive approach and rely on technology to get immediate alerts on suspicious accounts and transactions.

Non-financial institutions are also required to identify such financial crimes and report the suspicious activities to the concerned authorities.

International bodies like FATF, MENAFATF, and the Egmont Group of FIUs are working together with law enforcement agencies locally and internationally towards the identification & mitigation of these financial crimes. Many countries have joined hands towards stopping these crimes at large.

Financial and non-financial institutions are required to keep a vigilant eye on additional suspicious activities, which include:

Prominent transactions indicating layering in ML/FT

Cash deposits into an account are withdrawn immediately. Criminals ensure that they do not cross the transaction and deposit cash limits. If regular transactions barely fall behind the threshold or add up precisely to the prescribed limit, then it’s a red flag.

AML compliance services such as AML/CFT Policy, Controls & Documentation, Annual AML/ CFT Risk Assessment Report, andAML/ CFT health check-upswill help businesses understand if they are following the proper procedures to prevent money laundering and financing of terrorist activities.

Peeling Back the Layers: How Layering Techniques are Used in Money Laundering (3)


Why is layering considered to be the most difficult stage of money laundering to detect?

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Layering is the second stage of money laundering. What makes layering in money laundering difficult to detect is the way it is broken down into smaller transactions and the conversion of money from one form to another.

What is layering in financial crime?

Layering is the second stage in money laundering. It is a structuring process in which criminally derived funds are legalized and their ownership and source is disguised.

How to identify layering in the fight against money laundering?

Several red flags indicate the layering of funds in money laundering. Banking transactions involving large cash deposits into various banks, international bank transfers, investment and resell of jewellery, art, and other high-value items, fund transfer using shell companies, etc., indicates that the funds are being layered to make the detection of their origin as difficult as possible.

What is the main goal of the layering stage of money laundering?

The main goal of the layering stage of money laundering is to make the detection of the source of illicit money as difficult as possible.

What is the difference between placement and layering in money laundering?

The main difference is that placement is the first stage in money laundering, and layering is the second stage.

Placement involves the introduction of illicit gains into the financial system to start the money laundering process. But in layering, the launderer tries to make complex transactions after introduction into the financial system to hide its true origin.

Examples of placement involve purchasing antiques, paintings, etc. Examples of layering involve the creation of Trusts to hide the origin of illicit funds, Fund or wire transfers via electronic media, etc.

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