Notes from the desk.
Short pieces on the casework behind the game — typologies, judgement calls, and the alerts that look like something and turn out to be nothing.
Screening at onboarding is not screening at payment
Why customer screening and payment screening catch different things, and how to handle a name match you can neither evidence nor rule out.
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How sanctions evasion actually works
How sanctions evasion works in practice — ownership layering, front companies, AIS gaps, falsified origin — and what a bank can actually see from payments.
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Sectoral, blocking and sanctions that are neither
Blocking versus sectoral sanctions, plus the measures that fit neither — and why a name-matching engine misses most of them.
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Sanctions ownership: why the fifty per cent rule catches people out
How the sanctions fifty per cent ownership test works in practice: aggregation, indirect chains, control without shares, and where jurisdictions diverge.
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Correspondent banking and the nested relationship problem
How nesting changes correspondent banking risk, the questions a respondent must answer, and how to use payment message data as your only real visibility.
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Shell companies, shelf companies, and the difference that matters
How to tell a shell company from a shelf company on a registry extract, and which combinations of facts actually justify escalation.
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Third-party payments: when someone else's money moves through an account
How to tell ordinary third-party payments from funnel account activity: sender diversity, onward speed, and whether the customer knows who paid them.
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Trade-based money laundering: reading an invoice for red flags
How to read a commercial invoice for trade-based money laundering red flags: unit price checks, phantom shipments, multiple invoicing and misdescribed goods.
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Cash-intensive businesses: how to assess whether the takings are plausible
How to test a cash business's declared takings against footfall, opening hours, staffing and card-to-cash ratios — without de-risking the whole sector.
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