AML Scenario Gap Finder
Typology group

Rapid movement and pass-through

Money that arrives and leaves before it rests: in-and-out flows, transfers between related accounts, internal accounts used to break the trail, and loans paid down from nowhere.

The typologies

4
Typology and a scenario that places thereChannelsBSA
Rapid movement of fundsRapid movement: funds in and out within 48h > 80%ACH WDM WIN RTP P2PBSA BSA-AML-15
Transfers between related accountsCircular transfers between related party accountsACH WDM RTP ONLBSA BSA-AML-15 · BSA BSA-CDD-3
Internal and suspense accountsCustomer funds routed through suspense accountsWDM WINBSA BSA-AML-15
Loan paid down from unexplained fundsLoan paid down early with funds from an unrelated third partyACH WDM LNSBSA BSA-AML-15 · BSA BSA-CDD-3