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Description
I'm an AML analyst using AMLSim to generate test data for ML models. The current alert
patterns focus on traditional typologies (fan-in, fan-out, cycles) but are missing modern
money laundering schemes that we see in real-world investigations.
For example, the current patterns don't include:
- Trade-based money laundering (TBML)
- Cryptocurrency integration schemes
- Nested structures (multiple layering levels)
- Micro-structuring (many small transactions just below thresholds)
This makes it hard to test detection models against emerging threats.
Solution:
Add new money laundering pattern types to the alert pattern library:
- Trade-Based ML: Over/under invoicing patterns with corresponding trade transactions
- Cryptocurrency Integration: Cash → Crypto → Cash cycles
- Advanced Structuring: Multiple accounts making coordinated small deposits
- Nested Layering: 3+ levels of intermediary accounts before integration
- Cross-Border Shells: Transactions through multiple jurisdictions with shell companies
These should be added as new alert pattern templates that users can configure in
alertPatterns.csv.
Alternatives
- Manual pattern creation: Could manually create these patterns, but it's time-consuming
and error-prone - Modify existing patterns: Current patterns are too simple to represent these complex schemes
- Use real data: Can't use real data due to privacy regulations
Additional context
Why this matters:
- FATF Red Flag Indicators include these typologies
- FinCEN advisories highlight trade-based ML and crypto risks
- Realistic test data improves model performance on real investigations
Pattern references:
- FATF Trade-Based ML Report (2020)
- FinCEN Cryptocurrency Advisory (2019)
- Wolfsberg Correspondent Banking Principles
Impact:
- Better ML models trained on realistic patterns
- More comprehensive testing coverage
- Helps researchers address current AML challenges
I can provide detailed pattern specifications and examples from regulatory guidance
if helpful!
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