Seventeen distinct money laundering techniques have been described in TRACFIN’s latest AML/CFT Threat Assessment, providing a revealing look at the evolving tactics used by criminals in France and beyond. By analyzing real-life case studies, TRACFIN delivers practical insight into how illicit funds are moved through sectors such as art, crypto-assets, real estate, gambling, and more, giving compliance professionals an up-to-date resource for identifying and mitigating financial crime risks.

TRACFIN Typologies: Money Laundering Methods Revealed

TRACFIN’s 2023–2024 report highlights that effective AML/CFT efforts depend on a collective response from both public and private sectors, informed by up-to-date intelligence and shared learning. Their typology-driven approach organizes case studies by the underlying sector, predicate offence, or laundering channel, making it easier for compliance teams to benchmark their own controls and spot emerging trends.

Accounting Manipulation

Criminals often manipulate company accounts to hide illicit gains or fabricate assets. TRACFIN details schemes involving false accounting entries, overvaluation of assets, and the issuance of bogus invoices between linked entities. In one case, a listed company issued a €20 million share premium in exchange for ineffective software, with parallel flows of funds and falsified records designed to reduce the group’s tax liabilities and obscure the true source of income. Warning signs include high-value invoices for dubious business, companies with disproportionate payrolls, and multiple transactions between entities with no legitimate connection.

Art Market Vulnerabilities

The art world’s opacity, high-value transactions, and weak regulatory oversight make it a magnet for laundering illicit proceeds. TRACFIN reports cases where unrelated construction and food service companies pooled resources to purchase artworks at auction, funnelling criminal proceeds through seemingly legitimate purchases. These transactions were often paid for by foreign intermediaries unconnected to the corporate activity, with requests to alter invoices or buyer details to mask beneficial ownership. The report underscores the importance of verifying the relationship between buyers, payment sources, and the declared business activities of all entities involved.

Crypto-Assets and Decentralized Finance (DeFi)

Cryptocurrencies and DeFi ecosystems are at the heart of new money laundering typologies. The “rug pull” scam, for example, involves fraudsters launching a digital token, attracting investments via social media, and then suddenly withdrawing all liquidity, leaving investors with worthless assets. TRACFIN stresses that promotion of blockchain projects, use of blacklisted crypto-assets, and dramatic price increases in NFTs are all red flags for reporting entities. The report also outlines cases where crypto was used to finance child exploitation or to obscure cross-border transfers for other criminal purposes.

Real Estate and Luxury Goods

Real estate remains a classic channel for cleaning dirty money, often through undervalued sales to related parties, purchases by foreign shell companies, or transactions involving individuals subject to asset freezes. TRACFIN’s case studies reveal scenarios in which properties are sold at below-market prices to linked entities, then quickly resold at inflated values, allowing criminals to inject illicit funds into the legitimate financial system. Similarly, the purchase of high-value goods, such as art and jewelry, using cash or third-party accounts remains a common tactic.

Gambling and Betting

Gambling establishments, both land-based and online, are frequently abused to launder funds. TRACFIN describes cases where cash proceeds are deposited abroad, then moved through a series of gambling activities—sometimes with the help of complicit insiders—to create the appearance of legitimate winnings. Techniques include the purchase of winning tickets for resale, exceptional returns that do not align with a gambler’s known resources, and unexplained payments between unrelated parties.

Emerging Techniques: Criminal Innovation in Money Laundering

Criminal organizations are constantly evolving, taking advantage of new technology and regulatory blind spots. TRACFIN’s case studies offer insight into several emerging trends.

Use of Shell Companies and Trusts

Shell companies and undeclared trusts provide an additional layer of anonymity for criminals looking to disguise beneficial ownership. For example, one French resident used a series of offshore shell entities and a trust in a FATF grey-listed country to obscure connections with a consulting firm. Funds were cycled through neobanks and traditional accounts in different jurisdictions, making it difficult to trace their true origin. These schemes typically involve cross-border transactions, transfers to or from jurisdictions with weak AML controls, and entities not registered in national trust registries.

Fraud Against Public Finances

Fraudulent use of government aid schemes—such as energy efficiency grants or tax incentives for overseas investment—represents a significant threat. TRACFIN’s report details cases where fake construction projects, forged invoices, and shell companies were used to siphon public funds. Such schemes frequently involve the use of unregistered or non-certified subcontractors, lack of physical evidence for claimed investments, and the diversion of grant money to unrelated accounts.

Social Media and Virtual Economies

The increasing popularity of social media platforms with integrated financial features has opened new avenues for money laundering and terrorist financing. TRACFIN provides examples where “virtual gifts” sent to influencers were actually being funneled to extremist groups. Because these payments are processed within closed platforms, tracing the ultimate beneficiary is difficult without platform cooperation. Similar vulnerabilities exist with gaming and content subscription sites that support anonymous or pseudonymous payments.

Crowdfunding and Online Fundraising

Crowdfunding sites can be exploited to disguise the true purpose of donations. Criminals open fundraising accounts for ostensibly legitimate causes, only to redirect funds to extremist activities, personal expenses, or high-risk destinations. These schemes often involve sudden changes in account behavior, large numbers of small donations from disparate sources, and transfers to geopolitically exposed regions.

Corruption and Unlawful Taking of Interest

Public procurement and government contracts remain vulnerable to corrupt practices. TRACFIN highlights cases where public officials award contracts to companies in which they have a hidden interest, often by engineering short tender deadlines or engaging in fictitious subcontracting. Red flags include unusually favorable contract awards, quick payments for undelivered services, and complex relationships between bidders and public officials.

Warning Signs: TRACFIN’s Practical Indicators for Reporting Entities

A major strength of the TRACFIN report is its systematic identification of warning signs for use in compliance programs. These warning signs are derived from real-world investigations and are intended to be incorporated into monitoring systems across all reporting entities. Common indicators include:

• Multiple active bank accounts or payment cards for a single individual, especially if linked to prepaid or neobank products.
• Large cash deposits inconsistent with declared income or business activity.
• Purchases and financial flows between entities with no legitimate economic rationale.
• Use of companies or trusts registered in high-risk or low-tax jurisdictions.
• Involvement in business sectors known for high AML risk (e.g., art, real estate, luxury goods, crypto).
• Transactions involving politically exposed persons (PEPs) or individuals with negative media profiles.
• Rapid resale of high-value assets with unclear funding sources.
• Unusual patterns of cross-border fund transfers, especially involving countries under sanctions or on regulatory watch lists.

Case Study Highlights: Real Scenarios from TRACFIN

The Girardin Tax Incentive Scam

Investors from mainland France were lured into a complex scheme promising tax breaks for investments in overseas territories. In reality, no properties were built, and forged invoices and shell companies were used to create the illusion of legitimate transactions. Investors received outsized tax deductions, while the scheme’s architects siphoned off millions in public funds.

Cryptocurrency Child Exploitation Payments

A French citizen used multiple virtual asset service providers (VASPs) and small-sum cryptocurrency payments to access illegal content on darknet platforms. The criminal’s accounts received numerous small transfers from different VASPs, raising red flags due to the low transaction values and the customer’s profile.

Complex Real Estate Laundering

A property company, controlled by a single individual, sold assets at steep discounts to related companies. These assets were then rapidly resold to unrelated parties, including foreign shell companies. The complex ownership structure and undervaluation allowed the beneficial owner to obscure the original source of the funds and bypass asset freezes.

The TRACFIN Approach: Collaboration and Deterrence

TRACFIN emphasizes that its work is both analytical and preventive. By sharing anonymized case studies and warning signs, the agency aims to improve the detection capabilities of all stakeholders. Reporting entities are encouraged to use these insights to refine their transaction monitoring, train staff, and foster a compliance culture that keeps pace with emerging risks. TRACFIN’s commitment to regular feedback and dialogue with the financial sector—such as through its annual Forum—demonstrates the value of a collaborative approach in combating financial crime.

Conclusion: Strengthening AML Defenses with TRACFIN’s Guidance

TRACFIN’s annual threat assessment offers invaluable insights into the evolving landscape of financial crime. Its comprehensive documentation of laundering techniques, sectoral vulnerabilities, and practical warning signs provides compliance professionals with the tools they need to stay ahead of increasingly sophisticated criminals. Whether through innovative use of technology, exploitation of regulatory gaps, or the abuse of new financial platforms, criminals will continue to evolve—but so too must the vigilance and expertise of those tasked with stopping them.

Regular consultation of TRACFIN’s guidance and active participation in AML/CFT knowledge sharing will be critical for financial institutions and non-financial actors alike. By internalizing these lessons and fostering stronger public-private partnerships, the integrity of the financial system can be better protected against the ever-changing tactics of financial criminals.

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Related Links

• European Banking Authority: AML Guidelines
• TRACFIN Official Website
• French Ministry of Economy – AML/CFT Resources
• FATF Recommendations

Other FinCrime Central Articles About Money Laundering Techniques

• In the Shoes of a Money Launderer: 11 Techniques to Open Bank Accounts Anonymously
• 5 Key Techniques to Track Illicit Real Estate Investments for Money Laundering
• The Dark Side of P2P Money Transfers: How Criminals Launder Billions

Source: TRACFIN Full Report

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