Typology Discriminators

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Last updated 11:16 PM on 10/4/26
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12 Terms

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Structuring

Cash kept just under $10,000, or split the same day across branches, plus knowledge of or intent to avoid the CTR. An indicator is not proof: without intent you need more.

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Pass-Through / Rapid movement

In, then out within hours or a day: 85-95% + Forwarded; balance falls back under $800-$2,000

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Funnel Account

Cash deposited at ATMs or branches in several distant states, then withdrawn or spent in one home location.

4
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Layering

Extra hops that obscure the source of refunds to unrelated third parties, circular owner loans relabeled “capital contribution”, oversized flows between unrelated industries and jurisdictions

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Money mule

Personal account receives from unrelated businesses or individuals and forwards onward.

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Concealment via personal accounts

Business revenue collected in employees’ or the owners personal accounts hides the real flow of funds

7
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Beneficial Ownership / shell

Offshore trust, layered holding companies, a director on 150+ companies, no employees or operations. Concern = natural-person owners cannot be identified

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Payment Diversion

Long-standing supplier suddenly says “pay this new consulting company instead”; no link: opaque owners

9
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Corruption / PEP

Parties who need a government decision pay a PEP’s close relative for vague “consulting” with little works shown

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