AML Typology & Rules Reference — CAMP by Riskpro

CAMP · Certified Anti Money Laundering Professional

AML Typology & Monitoring Rules Reference

A working reference of common money-laundering typologies (structuring, layering, trade-based ML, sanctions evasion, and more) and the transaction-monitoring red flags used to detect each one.

Part of a Live, Graded Simulation

This reference sits alongside Riskpro's CAMP (Certified Anti Money Laundering Professional) simulation — a live, graded case-management exercise where you triage and investigate realistic AML alerts exactly as an L1 analyst or L2 investigator would on a real compliance desk. Every case pulls its own customer profile, transaction ledger and red flags, and every decision you make, including how you write up your rationale, is scored against a deterministic rubric, with a Director and Investigation Lead guiding you through the programme. It's the practical counterpart to this reference: read the theory here, then apply it against real alerts inside the simulation.

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Typologies

Structuring / Smurfing
Breaking a large sum into multiple smaller transactions, often just under a reporting threshold, to avoid triggering currency transaction reporting.
Layering
Moving funds through multiple accounts, entities or jurisdictions in rapid succession to obscure the audit trail back to the original source.
Trade-Based Money Laundering
Misrepresenting the price, quantity or quality of goods in import/export documentation to move value across borders under the guise of trade.
Shell / Front Company Layering
Using companies with no genuine business activity, opaque beneficial ownership, or a registered address that resolves to a residential unit or mail drop.
Rapid Movement of Funds
Funds are deposited and withdrawn or transferred out again within an unusually short window, with little or no dwell time in the account.
Funnel / Pass-Through Account
An account receives many small deposits from geographically dispersed sources and consolidates them into one or a few large outbound transfers.
Sanctions Evasion
Attempting to transact with a sanctioned individual, entity, vessel or jurisdiction, often via name variants, intermediaries or front companies.
PEP / Corruption-Linked Flows
Activity connected to a politically exposed person that is inconsistent with their declared official income, or that follows shortly after a change in office.
Proliferation Financing
Transactions linked to dual-use goods, embargoed technology, or entities associated with weapons proliferation networks.
Cryptocurrency Mixing/Tumbling
Use of mixing services, chain-hopping, or many small in/out crypto transfers designed to break the on-chain link between source and destination of funds.
Unusual Cash Activity
Cash deposits or withdrawals inconsistent with the customer's declared occupation, income, or historical account behaviour.
Adverse Media Nexus
Credible negative news coverage linking the customer or a close associate to fraud, corruption, organised crime or terrorism.

Monitoring Rules & Red Flags (13)

R017 — Structuring: Avoidance of Reporting Thresholds

Structuring / Cash · Structuring (Smurfing)

  • 5 cash deposits within 7 days, each between $3,000–$9,999, meeting the rule's minimum count
  • Aggregate of $40,350 well above the $10,000 threshold
  • Deposits spread across 3 branches and 2 channels
  • Declared occupation unverified; no business licence on file

R018 — Structuring: Potential Structuring in Cash and Equivalents

Structuring / Cash · Structuring (Smurfing)

  • 5 monetary-instrument deposits over 7 days, each under the reporting threshold, meeting the minimum count
  • Aggregate £24,100 exceeds the aggregate threshold
  • Customer declared unemployed; source of instruments unclear
  • Instruments from different named issuers with no apparent connection

R019 — Large Reportable Transactions

Structuring / Cash · Structuring (Smurfing)

  • 6 transactions within 3 days, each below the individual reporting cap, meeting the minimum count of 6
  • Aggregate ₹40,90,000 far exceeds the reportable threshold
  • Deposits across 4 different branches within 3 days
  • Declared occupation as “forex consultant” has no matching licence or registration on file
  • One deposit is a demand draft from an unrelated named third party

R020 — Single or Multiple Cash Transactions: Possible CTR

Structuring / Cash · Structuring (Smurfing)

  • 5 deposits over 7 days meeting the minimum count
  • Aggregate £41,300 exceeds the aggregate threshold
  • Deposits made at two different branch locations
  • 5 cash deposits over 7 days meeting the minimum count, each between $7,900–$9,400
  • Aggregate $44,300 far exceeds the reportable threshold
  • No declared business registered under the customer's stated “consulting” occupation
  • Deposits split across three branches and two channels

R021 — Single or Multiple Cash Transactions: Large Significant Transactions

Structuring / Cash · Structuring (Smurfing)

  • 6 large cash transactions in 3 days meeting the minimum count
  • Aggregate €48,100 far exceeds the threshold and the account's declared income level
  • Declared part-time retail income wholly inconsistent with cash volume
  • Deposits alternate between two branches on each of the three days

R034 — Structuring: Deposits/Withdrawals of Mixed Monetary Instruments

Structuring / Cash · Structuring (Smurfing)

  • 6 mixed monetary instruments deposited in a single day, meeting the minimum count
  • Aggregate $30,500 far exceeds the threshold
  • Mixed instrument types (money orders, cashier's cheques, travelers cheques) from multiple unnamed issuers
  • Declared occupation as import/export broker unlicensed and unverified

R061 — High Risk Electronic Transfers

Structuring / Cash · Sanctions Evasion — Shell Entities

  • 5 wire transfers in 5 days to a single beneficiary with incomplete address information, meeting the minimum count
  • Aggregate £44,200 exceeds the threshold
  • Beneficiary jurisdiction flagged as monitored under the rule's geography filter
  • Company onboarded only 7 months prior with no established trading history
  • No underlying invoices or trade documentation attached to any transfer

R071 — Peer-to-Peer (P2P) Payment Structuring and Aggregation

Structuring / Cash · Money Mule / Layering

  • 5 P2P inflows from unrelated senders across 3 platforms within 2 days
  • Aggregate inflow $10,300 immediately followed by a near-matching $10,100 outbound wire
  • Account average balance ($1,800) inconsistent with this throughput
  • Sender names show no apparent relationship to the account holder or each other
  • Rapid in-and-out pattern consistent with mule-account layering

R022 — Anomalies in ATM, Bank Card: Excessive Withdrawals

Cards / ATM · Money Mule / Layering

  • 18 ATM withdrawals within 30 days (over the count threshold), against typical usage of 3–4/month historically
  • €9,800 in electronic transfer received then rapidly withdrawn as cash across multiple locations within 6 days
  • Withdrawal pattern begins immediately after the inbound transfer, not on the customer's normal payday cycle
  • Sender of the inbound transfer has no apparent relationship to the customer

R045 — Anomalies in ATM, Bank Card: Foreign Transactions

Cards / ATM · Account Takeover / Identity Fraud

  • Transaction in London followed by a transaction in Lagos, Nigeria only 2 hours later — physically impossible for the same cardholder
  • Customer has no travel history or prior foreign transactions on file
  • Foreign spending of £4,800 within 3 days far exceeds normal monthly card usage of £300–£400
  • Nigeria flagged as a monitored jurisdiction under the rule's risk parameters

R059 — Anomalies in ATM, Bank Card: Structured Cash Deposits

Cards / ATM · Structuring (Smurfing)

  • 6 CDM deposits over the alert window, meeting the minimum count
  • Every deposit clusters just under $1,000, a level notably consistent for a self-employed driver but also individually deliberate-looking
  • Deposits alternate between two branches

R084 — Social Engineering, Authorized Push Payment (APP) Fraud Proceeds Monitoring

Fraud Convergence · Money Mule / Fraud Convergence

  • Two large inbound wires from unrelated individuals within days, each referencing romantic/emergency/investment context in the memo field — classic APP fraud victim messaging
  • Combined inbound of $25,700 far exceeds the customer's near-zero average balance and declared unemployed status
  • Nearly the entire inbound amount transferred onward to a crypto exchange within 48 hours
  • Account opened only 3 months prior with no established legitimate income pattern

R087 — Account Takeover and Identity-Based Fraud Indicators

Fraud Convergence · Account Takeover / Identity Fraud

  • Login from a new device and unusual geolocation the customer has never used before
  • Password and phone number changed within minutes of the unusual login
  • New payee added and a large transfer executed within the same session, all within 60 minutes
  • Customer's historical login pattern is exclusively from UK IP addresses over 11 years

This reference is part of Riskpro's CAMP — Certified Anti Money Laundering Professional programme, which pairs it with a live, graded alert-investigation simulation for L1 and L2 AML analysts.

Register for CAMP →