Gatekeepers

Criminals rarely set up complex structures alone. They need someone to form companies, open accounts, draw up trusts, handle property deals or give an air of respectability. People who do this work are gatekeepers. They often hold client money and advise on structures, so they see what banks cannot. Under FATF standards, many of them fall in the group of designated non-financial businesses and professions and must run customer checks and report suspicious activity. Real estate agents are included because property is a favoured place to park illicit wealth, and an agent can enable a purchase by accepting funds from a doubtful source. Legal professional privilege complicates matters, since lawyers may be barred from sharing some client details. Banks treat clients introduced through such professionals with extra care. Take away the willing or careless professional and many laundering schemes lose the respectable front they depend on.

A company service provider sets up forty shell companies for one overseas client, each with a different local director who has no real role. Several then open accounts at a bank and receive large transfers. The bank's reviewers notice the same provider address on all of them and ask the provider about its client checks before accepting further business.