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Add Modern AML Typologies to Alert Pattern Library #87

@matheusybsen

Description

@matheusybsen

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:

  1. Trade-Based ML: Over/under invoicing patterns with corresponding trade transactions
  2. Cryptocurrency Integration: Cash → Crypto → Cash cycles
  3. Advanced Structuring: Multiple accounts making coordinated small deposits
  4. Nested Layering: 3+ levels of intermediary accounts before integration
  5. 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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