Layering in Money Laundering: What You Need to Know

In the complex world of financial transactions, "Layering in Money Laundering" has emerged as a dark art, masterminded by those looking to camouflage the illicit origins of their wealth. This pivotal second stage in the money laundering cycle crafts a complex web of transactions aimed at disorienting regulatory bodies and blocking traces.

Despite the best efforts of law enforcement agencies, preventing layering remains a significant challenge in combating money laundering. Organizations must understand this process and take proactive measures to prevent it.

Consequently, to address this issue, businesses and financial institutions have started utilizing Anti-Money Laundering (AML) compliance suites as a formidable weapon to detect and thwart layering attempts.

It is crucial for organizations to understand the process of layering and take proactive measures to prevent it. In this article, we will explore the concept of Money Laundering Layering in detail, including its operational mechanisms.

What is Layering in Money Laundering?

Layering is a sophisticated process that aims to conceal the source of illicit funds and make it nearly impossible to trace them back to their origin. Illicit funds are traced by utilizing a range of complicated financial transactions through multiple banks and countries to complicate their tracking.

Layering is common among money launderers involved in various criminal activities, such as drug trafficking and corruption. The layering stage is a crucial step in money laundering, as it allows criminals to move their ill-gotten gains without drawing attention, making it more challenging for law enforcement agencies to detect and prosecute them.

You can learn more about layering in AML with this example:
A drug trafficker initially deposits $500,000 in a bank account (placement). They then create a shell company, "ABC Holdings," which purchases a $1 million property through a mortgage, utilizing the initial $500,000 as a down payment. To further obscure the source, ownership is shifted to an offshore entity, and the offshore company repays the initial bank loan with funds from another mortgage. The property is eventually sold for $1.2 million, resulting in a $200,000 profit, which is integrated into the legitimate economy. The intricate financial transactions, shell companies, and property dealings in this layering process make it extremely challenging for authorities to trace the illicit funds to their source.

Layering is the second of three core money laundering stages: placement, layering, and integration. Like placement, layering is a technique with one primary objective: masking the source of illegally accrued wealth by making the illegal funds appear legitimate by passing them through multiple layers of financial transactions or instruments.

The goal is to make the initial "dirty money" as difficult to trace as possible through a labyrinth of alternative dealings and transfers, often spanning across multiple banks, usually in different countries.

Money laundering layering becomes more difficult to detect if the funds are converted into different currencies or moved through other financial systems. For instance, if money laundering transactions are carried out using US Dollars, UAE Dirham, and Saudi Riyals, it will be harder for law enforcement agencies to trace the illegal origin of the funds. This is because the different currencies and financial systems create multiple layers of complexity, making it more challenging to follow the trail of money and detect criminal activity.

Examples of Layering in Money Laundering

Money Launderers use different methods to create complex layers of financial transactions designed to confuse and cloud the paper trail and make it difficult for authorities to trace them back to their source. 

Navigating through the money laundering stages, particularly during layering, illicit actors conceal their financial activities by investing in high-value assets such as real estate or expensive artwork, which are then sold to introduce the assets back into the financial ecosystem, effectively 'cleaning' the money. Alternatively, they might utilize a network of shell companies to mask true ownership and disrupt traceability.

Another example of layering in money laundering involves the utilization of cryptocurrency. Perpetrators could use illicit funds to purchase cryptocurrency, transferring it among various wallets and exchanges, thereby clouding the transaction trail before converting it into fiat currency. This method utilizes the relative anonymity of cryptocurrency transactions to shield the origins of the funds.

So, to group everything, here are some examples of how layering in money laundering can be conducted:

Example 1 - Shell Companies and Complex Corporate Structures

Step 1: A criminal sets up multiple shell companies in various locations, particularly where the regulatory environment is more relaxed or secretive.

Step 2: Money is transferred through the accounts of these shell companies in a series of rapid, large transactions.

Step 3: Funds are moved between different accounts, often crossing borders and changing currencies, to further hide their origins.

Step 4: The shell companies may engage in transactions with each other, such as "buying" and "selling" services or goods, without any actual exchange of physical commodities.

Example 2: Over- and Under-Invoicing of Goods and Services

Step 1: The importer and exporter work together to undervalue the exported goods. 

Step 2: The importer pays the actual value of the goods but uses the undervalued invoices to report lower costs for accounting purposes. 

Step 3: The difference between the invoiced price and the actual payment is laundered money, which is now harder to trace since it appears part of legitimate business transactions.

Example 3: Investing in High-Value Items

It's a three-step process where illegally obtained funds are used to buy expensive items like art, antiques, or jewelry in the first step. 

In step 2, these items are sold, and the money obtained from the sales is considered "clean" money that is hard to link to any criminal activity. This step is crucial in disguising the initial source of the illegal funds. 

Finally, these high-value transactions may occur multiple times, with items being bought, sold, and resold several times, creating multiple layers of transactions that make it difficult to trace the initial source of the illicit funds.

Example 4: Digital Currencies

The process involves three main steps. 

First, the illegal funds are used to buy digital currencies such as Bitcoin, which makes it difficult to trace the money. 

Second, these digital currencies are often moved through multiple wallets and cryptocurrency exchanges, and mixing services may be used to combine transactions, making it even harder to follow the trail. 

Finally, the digital currencies are converted into fiat currency and returned to the person who laundered the money, with a hidden transaction history.

These examples of layering in money laundering illustrate how layering can create intricate networks of transactions, which can be immensely challenging for authorities to trace back to the source of illicit funds. The intention is always to create a web of challenging transactions to untangle, thereby safeguarding the criminals from detection and ensuring that the laundered money cannot easily be linked back to them.

How Does Layering in Money Laundering Work?

Understanding the machinations of layering demands a deep dive into its processes. At its core, it's a deliberate process where illegal money is being moved through a series of transactions to keep its starting point hidden.

Fragmentation of Funds - Large sums of illicit money are initially broken down into smaller, less suspicious amounts.

Diversification of Transactions - These fragmented sums are then disseminated across various accounts and often through different financial institutions, utilizing many transaction methods.

Global Movement - Funds may be moved internationally, exploiting discrepancies in regulatory frameworks between countries and leveraging offshore accounts to complicate traceability further.

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Methods of Layering in Money Laundering

Layering leverages many methods, each aimed at embedding complexity and confusion into the transaction trail. Here, different techniques, such as using alternative banking platforms, cash-intensive businesses, digital currencies, and the purchase of assets, are manipulated to convolute the money trail.

Money laundering involves disguising the origins of illegally obtained funds. Here are ten methods commonly used:

1. Establishing shell companies to move money between entities.

2. Smurfing by depositing smaller amounts and transferring funds between different banks.

3. Buying and selling high-value items or investing in the stock market.

4. Over/under-invoicing, multiple invoicing, over/under-shipping.

5. Using cryptocurrencies and mixing services.

6. Buying casino chips or online gambling credits with illicit money and later cashing them out as ‘winnings’ or using online gambling platforms.

7. Hiring accountants, lawyers, brokers, or establishing trust funds.

8. Utilizing offshore bank accounts or investing in properties or businesses in foreign countries.

9. Using cash-intensive businesses to co-mingle illicit funds with legitimate earnings or generating false billing.

10. Engaging in fake trade finance transactions or rapidly moving goods and funds in circular patterns across borders.

All these methods create complexity and can involve multiple jurisdictions, making it difficult for authorities to trace the money. Thus, combating money laundering requires coordinated and international efforts, utilizing regulatory frameworks and advanced technological tools.

Challenges in Detecting Layering in Money Laundering

Detecting layering in money laundering presents several challenges due to its intentionally obscured and convoluted nature. Some of these challenges include:

1. Complexity and Volume of Transactions

Criminals use layering in banking where they create complex transactional networks across multiple banks and financial institutions to conceal the trail of funds.

Due to high transaction volumes, the number of transactions that financial institutions handle daily can make it hard to identify suspicious activity.

2. Technological Advancements

Digital currencies can obscure transactions through blockchain technology, making tracing more difficult.

Utilizing online platforms and digital payment systems that facilitate rapid and often anonymized transactions.

Criminals employ advanced cybersecurity strategies to hide electronic trails and prevent detection.

3. Sophistication of Money Launderers

Money launderers continuously adapt their tactics to evade new regulations and detection strategies.

Using knowledgeable professionals, like lawyers and accountants, who might devise sophisticated layering schemes that are harder to detect.

4. Legal and Regulatory Limitations

Stringent data privacy laws might restrict information sharing between financial institutions and across borders.

Disparities in AML legislation and enforcement among different jurisdictions make unified action difficult.

5. Lack of Resources and Expertise

Institutions may lack personnel with specialized knowledge in detecting advanced money laundering schemes.

Regulatory bodies and smaller financial institutions may lack the resources necessary to invest in advanced detection technologies.

6. Emerging Financial Products

The creation of new and complex financial products and services that might be exploited for layering before regulations can catch up.

7. Integration with Legal Businesses

Layered money often intertwines with legitimate business revenue, making it difficult to separate illicit funds from lawful income.

In summary, these challenges require ongoing development and improvement of anti-money laundering strategies involving improved regulatory frameworks, international cooperation, technology adoption, and continuous learning and adaptation to emerging threats and methodologies in money laundering.

How is FOCAL Your Best Ally Against Money Laundering Layering?

Dealing with the complicated processes involved in layering requires smart technology and strategic planning. This is where FOCAL stands out, offering a robust suite of solutions tailored to empower your organization in the ceaseless battle against money laundering.

Advanced Analytics: FOCAL utilizes advanced analytics to identify suspicious patterns in financial transactions, providing a solid foundation for AML compliance and detection.

Holistic AML Compliance: Navigate the vast sea of regulatory obligations effortlessly with FOCAL’s comprehensive AML compliance solutions.

Real-Time Monitoring: Stay vigilant with FOCAL's real-time monitoring capabilities, ensuring no suspicious activity slips through unnoticed.

Case Management: Utilize FOCAL’s AML Case Management Steps to navigate an investigation efficiently, ensuring all regulatory obligations are met seamlessly.

With the pervasive threat of money laundering casting a shadow over the financial landscape, fortifying your organization’s defensive and responsive mechanisms is crucial. With FOCAL, navigate through the convoluted pathways of financial security confidently, ensuring your organization remains ahead of illicit financial activities.

Combating Layering: Anti-Money Laundering (AML) Regulations: Implementing stringent AML policies and conducting regular audits of financial institutions.

Know Your Customer (KYC) Protocols: Ensuring that financial institutions rigorously verify the identities of their clients and monitor transaction patterns.

Cooperation Between Jurisdictions: Enhancing international cooperation between regulatory bodies to effectively trace and halt the movement of illicit funds across borders.

Layering is a pivotal, complex, and often technologically sophisticated stage in money laundering, requiring equally sophisticated and coordinated efforts across jurisdictions and sectors to combat it effectively.

FAQs about Layering in Money Laundering

1. What are the three layers of money laundering?

The three layers of money laundering are:

  • Placement: This is the initial stage where illicit money is first introduced into the financial system. This might be through bank deposits, purchasing assets, or using the money for gambling.
  • Layering: The second stage involves conducting a series of complex transactions to obfuscate the origins of the money. The goal here is to confuse and cloud the paper trail by moving money across different banks or even countries, changing its form by buying and selling assets, and simply creating a complex web of transactions that are hard to trace back to their source.
  • Integration: The final stage involves reintroducing the 'cleaned' money back into the legitimate economy, making distinguishing it from legally-gained money difficult. The launderer might invest in legal business ventures, purchase high-value items, or undertake other activities that allow them to enjoy their profits without attracting attention.

2. What is layering and integration in money laundering?

Layering involves creating a complex series of financial transactions to disguise the origin of the illicit money. Layering in banking is essentially about moving the money in such a way (through various bank accounts across different countries or converting it through various asset purchases and sales) that it becomes difficult to trace back to its criminal source.

Integration in money laundering is the stage where the 'cleaned' or 'laundered' money is brought back into the legitimate economy, making it appear legally earned. The launderer might invest the money in legal business ventures, real estate, luxury goods, or other seemingly legitimate channels to enjoy their illegal gains without raising suspicion.

3. How can layering be combatted?

Layering can be combatted through various strategies, including:

  • Implementing robust Anti-Money Laundering (AML) policies and compliance programs that use algorithms and machine learning to detect suspicious activities and patterns of layering.
  • Regular training of employees in financial institutions to recognize signs of money laundering.
  • Establishing Know Your Customer (KYC) protocols to vet and understand clients' financial behaviors thoroughly.
  • Sharing information amongst financial institutions and across international borders to track money laundering activities.
  • Implementing stronger regulations and penalties for institutions that do not comply with AML laws.

4. Why is it important to combat layering?

Combating layering in money laundering is crucial for several reasons:

  • Preserve Integrity: Combating layering is vital part of AML to maintain the integrity of financial institutions and systems, ensuring they are not exploited for illegal activities.
  • National and Global Security: Money laundering often funds criminal organizations involved in activities such as drug trafficking, terrorism, and other illegal endeavors, which can be a threat to national and international security. 
  • Economic Stability: Allowing money laundering to occur unabated can undermine the economic stability of a nation and globally. It can distort asset and commodity prices and create unpredictable economic fluctuations.
  • Legal and Reputation Risk: Money laundering, even unwittingly, poses severe legal and reputational risks. Organizations found non-compliant with AML laws can face hefty fines and damage to their reputation, which can have long-term economic consequences.
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