Focus area · AML
Money-laundering risk where your money and your customers move
Money-laundering exposure is not only a bank's problem. Traders, manufacturers, real-estate and gaming companies carry it through customers, payment flows and partners. We show where it concentrates in your markets.
Not only a topic for banks
For obliged entities, a business-wide risk assessment is a legal duty. For everyone else, money-laundering exposure arrives through customers paying from third countries, cash-intensive channels, trade-based schemes and partners in high-risk jurisdictions.
The EU is replacing much of its directive-based regime with a directly applicable regulation and a new supervisory authority, and country lists change at every FATF plenary. A useful assessment takes a dated snapshot and says what is likely to move.
Legal frameworks we map
We map the regimes that apply to your footprint. Typical anchors:
- FATF Recommendations and country lists
- The global standard, the mutual evaluations of each country and the lists of jurisdictions under increased monitoring ('grey list') and subject to a call for action ('black list').
- EU AML package
- Regulation (EU) 2024/1624 (AMLR, largely applicable from July 2027), Directive (EU) 2024/1640 and the new EU Anti-Money Laundering Authority (AMLA); until then, the existing directives as transposed nationally.
- Germany: Geldwäschegesetz (GwG)
- Duties of obliged entities including risk analysis, customer due diligence and suspicious-activity reports to the FIU; money laundering as a criminal offence under § 261 StGB.
- EU list of high-risk third countries
- The European Commission's list, which triggers enhanced due diligence for EU obliged entities.
- US Bank Secrecy Act and related rules
- Relevant where you transact in US dollars or with US financial institutions; enforcement by FinCEN, the DOJ and banking regulators.
- Local AML regimes
- National AML laws, supervisors and FIUs in each country in scope, including beneficial-ownership registers and how accessible they are.
This is a risk analysis, not legal advice. Where a finding raises a legal question, we say so and you take it to counsel.
What we look at
External analysis
Your exposure as the outside world sees it.
- FATF status and mutual-evaluation results per country
- Supervisory and criminal enforcement in your sector
- Cases at your direct competitors
- Beneficial-ownership transparency and typical laundering typologies per country
- The Basel AML Index and similar indicators, read with their limits
Internal analysis (under NDA)
Your exposure as your own data shows it.
- Customer and payment-flow profile by country
- Third-party payments, cash and prepaid channels
- Intermediaries and partners in high-risk jurisdictions
- Internal suspicious cases, donations and sponsorships as potential channels
Seven focus areas, mapped against every source we read.
| Module 1 · External analysis | Module 2 · Internal analysis (NDA) | ||||||||
|---|---|---|---|---|---|---|---|---|---|
| Focus area | Law & regulation | Enforcement record | Sector cases | Competitor cases | Indicators | Internal cases | Business partners | Sponsoring, donations, memberships | Gifts & hospitality |
| ABCAnti-bribery & corruption | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Core source |
| AMLAnti-money laundering | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Where relevant | Not used |
| ATRAntitrust & competition | Core source | Core source | Core source | Core source | Where relevant | Core source | Where relevant | Core source | Where relevant |
| FRDFraud | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Where relevant | Where relevant |
| PRVData privacy | Core source | Core source | Core source | Core source | Where relevant | Core source | Where relevant | Not used | Not used |
| EXCExport control & sanctions | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Not used | Not used |
| HRTHuman rights | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Where relevant | Not used |
Highlighted row: AML · Anti-money laundering
Typical red flags
- Payments from or to third parties unrelated to the transaction
- Customers or partners in jurisdictions under increased FATF monitoring
- Complex or opaque ownership structures and nominee shareholders
- Over- or under-invoicing, unusual trade routes or vague goods descriptions
- A high share of cash or prepaid instruments in sales channels
- Frequent changes of bank accounts or payment instructions
- Real-estate, luxury-goods or gaming transactions without a plausible source of funds
Sources
- FATF mutual evaluations, follow-up reports and plenary outcomes
- Enforcement actions of supervisors, FIUs and prosecutors (e.g. BaFin, FCA, FinCEN)
- EU supranational and national risk assessments
- Court records and press, cross-checked against primary sources
- The Basel AML Index: a composite measure of country-level risk, not of your exposure
FATF lists change three times a year. The report states which plenary it reflects.
Typically exposed sectors
Exposure tends to be higher in financial services and payments, real estate, gambling, trade in commodities and high-value goods, and in any business with cash-intensive or complex cross-border payment flows.
A tendency, not a rating. Your actual exposure depends on business model, customer mix and footprint.
In your deliverable
- PDF: an AML chapter with regime overview, FATF status, enforcement picture, typologies, red flags and recommended measures
- Heatmap row per country × sector with the likelihood × impact rating
- XLSX: country table (FATF status, EU list, indicators with date), case register and scoring sheet
- With the internal module: payment flows and partners set against country risk
Questions on money laundering
We are not an obliged entity. Why look at money laundering?
Because your customers, payment flows and partners can carry the risk into your business. Companies outside the obliged sectors still face criminal liability, frozen payments and de-risking by their banks. The analysis shows where that exposure sits.
Does the analysis replace our risk analysis under the GwG?
It feeds it. For obliged entities, the country and sector picture is a core input to the business-wide risk analysis. The risk analysis itself, its approval and its documentation remain with you.
See where money-laundering risk enters your business.
Tell us your countries, sectors and payment channels. We come back with a scope proposal.