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Financial crime glossary

Plain-English definitions of the AML, KYC, sanctions and fraud terms that turn up in every policy, audit and regulatory exam. Written for practitioners, not for a dictionary.

Definitions are general and educational. Obligations differ by jurisdiction and by firm. See the disclaimer.

A

AML

Anti-Money Laundering

The collective framework of laws, regulations, controls and procedures designed to stop criminals disguising illegally obtained funds as legitimate income.

AMLA

Anti-Money Laundering Authority

The EU-level authority established to supervise higher-risk cross-border financial institutions directly and to drive consistency across national supervisors.

Alert

Alert

An output from a monitoring or screening system flagging activity for human review. An alert is not a suspicion; it is a prompt to form one.

APP

Authorised Push Payment Fraud

Fraud in which a victim is deceived into authorising a payment to an account controlled by a criminal. The payment is genuine; the authorisation is obtained by deception.

B

BO / UBO

Beneficial Owner

The natural person who ultimately owns or controls a customer, or on whose behalf a transaction is conducted, regardless of whose name appears on the account.

BWRA

Business-Wide Risk Assessment

A firm’s documented assessment of the financial-crime risks it is exposed to across customers, products, channels and geographies. It is the foundation every other control is justified against.

C

CDD

Customer Due Diligence

Identifying and verifying a customer and their beneficial owners, understanding the purpose of the relationship, and monitoring it on an ongoing basis.

CTF

Counter-Terrorist Financing

Controls aimed at detecting and disrupting funds raised for or used by terrorist organisations. Unlike laundering, the funds may be entirely legitimate in origin.

Correspondent

Correspondent Banking

An arrangement where one bank provides services on behalf of another, often cross-border. Higher risk because the correspondent has no direct relationship with the underlying customers.

Cuckoo

Cuckoo Smurfing

A laundering method in which criminal funds are deposited into the account of an innocent third party expecting a legitimate transfer, disguising the origin of the money.

D

DAML

Defence Against Money Laundering

A request for consent to carry out an act that would otherwise be a money-laundering offence. It must identify the specific act proposed and the specific criminal property involved.

De-risking

De-risking

Exiting or refusing entire categories of customer rather than managing their risk individually. Reduces a firm’s exposure but can push activity into less visible channels.

E

EDD

Enhanced Due Diligence

Additional scrutiny applied to higher-risk relationships: deeper source of wealth and funds enquiries, senior sign-off, and more frequent review.

EMI

Electronic Money Institution

A regulated firm authorised to issue electronic money and provide payment services without holding a full banking licence.

F

FATF

Financial Action Task Force

The intergovernmental body that sets global AML and CTF standards and assesses countries against them through mutual evaluations.

FIU

Financial Intelligence Unit

The national agency that receives, analyses and disseminates suspicious activity reports. In the UK this function sits within the National Crime Agency.

FP

False Positive

An alert that, on review, does not indicate the risk it was designed to detect. High false-positive rates are a tuning and data-quality problem, not simply a staffing one.

Fuzzy Matching

Fuzzy Matching

Screening logic that identifies near-matches to a watchlist entry, accounting for spelling variants, transliteration and name order.

G

Grey List

Grey List

Informal term for FATF’s list of jurisdictions under increased monitoring. Listing typically triggers enhanced scrutiny of related customers and payments.

Gatekeeper

Gatekeeper

A professional (lawyer, accountant, company formation agent) whose services can be used to give criminal activity a veneer of legitimacy.

I

Integration

Integration

The final stage of laundering, where funds re-enter the legitimate economy in an apparently lawful form, typically through property, business ownership or investments.

IDV

Identity Verification

Confirming that a customer is who they claim to be, using documents, electronic data sources, or biometric checks.

K

KYC

Know Your Customer

The process of identifying a customer, verifying that identity, and understanding their expected activity. The evidential base every later suspicion is measured against.

KYB

Know Your Business

The equivalent process for corporate customers, extending to ownership structure, control, trading activity and the people behind the entity.

L

Layering

Layering

The second stage of laundering: moving funds through multiple transactions, accounts or jurisdictions to obscure the audit trail back to the predicate offence.

3LoD

Three Lines of Defence

A governance model separating risk ownership (first line), oversight and challenge (second line), and independent assurance (third line).

M

MLRO

Money Laundering Reporting Officer

The named individual responsible for receiving internal suspicion reports, deciding whether to report externally, and acting as the firm’s focal point for financial-crime matters.

MLRs

Money Laundering Regulations

The UK regulations setting out AML and CTF obligations for regulated firms, including risk assessment, due diligence, record keeping and training requirements.

Money Mule

Money Mule

A person who receives and transfers criminal funds through their own account, sometimes knowingly, often recruited under the guise of legitimate work.

Model Risk

Model Risk

The risk that a detection or scoring model produces incorrect or unexplainable outputs. Growing in significance as machine learning enters monitoring and screening.

N

NCA

National Crime Agency

The UK law enforcement agency that houses the UK Financial Intelligence Unit and receives suspicious activity reports and DAML requests.

Nominee

Nominee

A person or entity appearing as the owner or director of record on behalf of someone else, frequently used to obscure true beneficial ownership.

O

OFSI

Office of Financial Sanctions Implementation

The UK body responsible for implementing and enforcing financial sanctions, including licensing and breach reporting.

Ownership & Control

Ownership and Control Test

The assessment of whether an entity is caught by sanctions because a designated person owns it above a threshold or otherwise controls it. That is often the harder half of the question.

P

PEP

Politically Exposed Person

An individual entrusted with a prominent public function, together with their family members and close associates. Status indicates higher risk; it is not an allegation of wrongdoing.

Placement

Placement

The first stage of laundering, where criminal proceeds first enter the financial system, historically through cash deposits and increasingly through digital channels.

Predicate

Predicate Offence

The underlying criminal activity that generated the proceeds being laundered: fraud, trafficking, corruption, tax evasion and similar.

pKYC

Perpetual KYC

An approach replacing fixed periodic reviews with continuous, event-driven refresh of customer information as data changes.

R

RegTech

Regulatory Technology

Technology applied to regulatory compliance: screening, monitoring, reporting, identity verification and case management.

Risk Appetite

Risk Appetite

The level and type of financial-crime risk a firm is willing to accept in pursuit of its objectives, formally set and approved at board level.

S

SAR

Suspicious Activity Report

A report submitted to the financial intelligence unit where there is knowledge or suspicion of money laundering or terrorist financing. Quality of narrative determines whether it is actionable.

Sanctions

Sanctions

Restrictive measures imposed on states, entities or individuals. Financial sanctions typically require asset freezing and prohibit making funds available, directly or indirectly.

SDD

Simplified Due Diligence

A reduced level of due diligence permitted where risk is demonstrably low. Simplified does not mean absent; the rationale still has to be evidenced.

SoW / SoF

Source of Wealth / Source of Funds

Source of wealth explains how a customer’s overall assets were accumulated; source of funds explains the origin of the specific money in a transaction. They are not interchangeable.

Structuring

Structuring / Smurfing

Breaking a large transaction into smaller ones to stay beneath reporting or detection thresholds.

Shell

Shell Company

A company with no meaningful operations or assets, which may be entirely legitimate but is frequently used to layer funds and obscure ownership.

T

TBML

Trade-Based Money Laundering

Disguising criminal proceeds through trade transactions: over- and under-invoicing, multiple invoicing, or misrepresenting the quality or quantity of goods.

Tipping Off

Tipping Off

Disclosing to a customer or third party that a suspicion report has been made or an investigation is underway, where that disclosure may prejudice it. A criminal offence in many jurisdictions.

TM

Transaction Monitoring

Ongoing review of customer activity against expected behaviour and known typologies, to identify patterns warranting investigation.

Travel Rule

Travel Rule

The requirement to transmit originator and beneficiary information alongside transfers, extended to crypto-asset transfers between virtual asset service providers.

U

UBO

Ultimate Beneficial Owner

The natural person at the end of a chain of ownership who ultimately benefits from or controls an entity, however many layers sit in between.

UWO

Unexplained Wealth Order

A court order requiring a person to explain how they obtained property where their known lawful income appears insufficient to have funded it.

V

VASP

Virtual Asset Service Provider

A business conducting crypto-asset activities such as exchange, transfer or custody on behalf of customers, and subject to AML obligations in most major jurisdictions.

Velocity

Velocity

The speed and frequency at which funds move through an account. Sudden changes are a common monitoring indicator, particularly in mule networks.

W

Wolfsberg

Wolfsberg Group

An association of international banks that publishes financial-crime principles and standardised due diligence questionnaires widely used between institutions.

Watchlist

Watchlist

A list of names screened against: sanctions designations, PEPs, adverse media or internal risk lists. Coverage and refresh frequency matter as much as the matching logic.

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