=Paper=
{{Paper
|id=Vol-2824/paper12
|storemode=property
|title=Money Laundering Risk Identification Algorithms
|pdfUrl=https://ceur-ws.org/Vol-2824/paper12.pdf
|volume=Vol-2824
|authors=Iryna Moіseіenko,Ivanna Dronyuk,Iryna Revak
|dblpUrl=https://dblp.org/rec/conf/itas/MoseenkoDR21
}}
==Money Laundering Risk Identification Algorithms ==
https://ceur-ws.org/Vol-2824/paper12.pdf
Money Laundering Risk Identification Algorithms
Iryna Moіseіenkoa, Ivanna Dronyukb and Iryna Revaka
a
Lviv State University of Internal Affairs, Gorodotska 26, Lviv, 79001, Ukraine
b
Lviv Polytechnic National University, Bandery 12, Lviv, 79013, Ukraine
Abstract
It is shown that the risks of money laundering are a type of danger associated with political,
social and economic activity. The methodological basis for identification of money laundering
risks is given. The monitoring data of money laundering risks are analyzed. The algorithms for
identification of money laundering risks in general case and partial case are developed on the
basis of data on owners and structure of property of financial transactions subjects.
Keywords 1
Risks of illegal income legalization, financial monitoring, proper verification of customers,
non-transparent ownership structure, beneficial owners
1. Introduction
The national system for preventing and combating money laundering needs to improve the
methodological framework for identifying and analyzing risks at the level of business entities. In
Ukraine, since 2016, national risk assessments have been carried out, which determine the typologies
of risks of money laundering and terrorist financing and typical schemes of their occurrence [1]. The
spread of these threats to economic security may result in the development of money laundering and
the support of financial flows of international terrorism and crime [2]. An important aspect of the study
of the legalization processes of illegally obtained income is the identification of money laundering risks
[3,4]. The article [5] shows that contextual institutional restraints and cultural factors have significant
impact on the possibility in the fight against terrorism an organised crime. The struggle for democracy
there is all over the world [6,7].
The special state body, the State Financial Monitoring Service of Ukraine (SFMS), is taking
enhanced measures to monitor the processes of money laundering, terrorist financing and the
proliferation of weapons of mass destruction. Financial monitoring is a set of measures taken by the
subjects of financial monitoring in the field of prevention and counteraction to legalization (laundering)
of proceeds from crime, terrorist financing and financing of proliferation of weapons of mass
destruction. Financial monitoring is a set of measures taken by the subjects of financial monitoring in
the field of prevention and counteraction to legalization (laundering) of proceeds from crime, terrorist
financing and financing of proliferation of weapons of mass destruction. The object of financial
monitoring is actions with assets related to the relevant participants in financial transactions that
conduct them; it is provided that there are risks of using such assets to legalize proceeds from crime, as
well as any information about such actions or events, assets and their participants.
Legalization (laundering) of proceeds from crime includes any actions related to a financial
transaction or transaction with proceeds from crime, as well as actions aimed at concealing or masking
the illegal origin of such proceeds, or possession them, the rights to such income, the sources of their
origin, location, movement, change of their form (transformation), as well as the acquisition, possession
or use of income obtained by criminal means [8].
IT&AS’2021: Symposium on Information Technologies & Applied Sciences, March 5, 2021, Bratislava, Slovakia
EMAIL: ko@lvduvs.edu.ua (Iryna Moiseienko); ivanna.m.droniuk@lpnu.ua (Ivanna Dronyuk); irarevak@gmail.com (Iryna Revak)
ORCID: 0000-0002-3140-461X (Iryna Moiseienko); 0000-0003-1667-2584 (Ivanna Dronyuk); 0000-0003-1755-2947 (Iryna Revak);
©️ 2021 Copyright for this paper by Iryna Moiseienko and Ivanna Dronyuk.
Use permitted under Creative Commons License Attribution 4.0 International (CC BY 4.0).
CEUR Workshop Proceedings (CEUR-WS.org)
2. Materials and methodologies
2.1. Identification of money laundering risks
The main criteria used to form certain classes of different risks for businesses in the field of money
laundering are as following:
1. The likelihood of risk of involvement in standard schemes of money laundering
2. The degree of uncertainty in the implementation of financial transactions
3. The consequences of dubious transactions
4. Potential for resilience / resistance to risks
5. Ability to recover from an emergency;
6. Scale and duration of consequences.
According to the updated methodology, the risk assessment scheme for money laundering
legalization contains the following stages: preliminary stage, identification (identification) of risks,
analysis, risk assessment and management [10,11].
A threat is interpreted as a person or group of persons whose activities may harm the country, society
and the economy. In other words, terrorist organizations and their supporters, their money, their past,
present and future activities in the field of money laundering.
Vulnerability is an area where a threat can be realized, or a factor that can help carry out that threat.
These can be structural components of the financial system, mechanisms for movement and storage,
services or goods in cash [8].
Consequences - the impact or harm of criminal activity on the financial system and / or institutions,
the economy as a whole, the population, the business environment, national and international interests,
the reputation and attractiveness of the country's financial sector to investors.
The likelihood of risks of money laundering is a function of the coexistence of the threat and
vulnerability to it. That is, risky events occur when a threat exploits a vulnerability. R - national risk
level of laundering and financial terrorism can be expressed as:
𝑅 = 𝑓(𝑇, 𝑉) × C, (1)
where R - risk function, T - threat; V - vulnerability; C - the consequences of the risk of laundering and
financial terrorism. Thus, the level of risk can be mitigated by reducing potential consequences, threats
or vulnerabilities [11].
The tools of cybercrime in typological schemes of money laundering include: forgery of payment
cards, access to remote banking systems, financial pyramids online, online casinos, denial of service,
DDoS attacks to obtain personal information about customers.
2.2. Monitoring the risks of money laundering
The results of the SFMS activities and the size of financial transactions that may be associated with the
legalization of funds and the commission of another crime, defined by the Criminal Code of Ukraine,
are shown in Table 1.
Table 1
Results of SFMS activity during 2019
The amount of
Direction of submission Submitted Generalized Additional financial
materials materials generalized transactions
materials (billion UAH)
Total 893 503 390 92,2
Investigation of the facts of
money laundering received 211 47 164 41,8
from acts of corruption
Source [9]
The number of financial statements with materials on the risks of money laundering is evidenced by
Table 2.
Table 2
Number of financial statements on money laundering risks
Years The total number of Is registered with Number of reports
financial institutions of DSFM submitted to the DSFM
the SFU
2016 1265 460 366
2017 1233 559 2285
2018 1299 699 3818
Source [9]
At the stage of functioning of business entities according to the information of the Ministry of Justice
of Ukraine till August 16, 2018 information on ultimate beneficial owners was provided by 23.2% of
the total number of registered legal entities (1,338,823 persons in total). According to the organizational
and legal form, they are distributed as shown in table 3.
Table 3
Status of information about the ultimate beneficial owners in 2018
Legal Form Number of Number of Number of JVs Number of JVs
registered joint registered joint that provided that provided
ventures (thousand ventures information on information on
units) (percent) CBD(thousand CBD
units) (percent)
Limited Liability 633 47,3 192 61,7
Company
Private enterprise 214 16 41 13,2
Farm 44 3,1 15 4,8
Total 1339 100 310 100
Source [12]
Any of the business entities from the given organizational and legal forms can be involved in
standard schemes of money laundering.
Problems of risk identification in the field of financial monitoring arise due to the following features:
• the presence of a large number of risks of current and long-term decisions;
• difficulties in identifying risks because they are closely related to each other;
• the variety of risks identified in different activities of the bank;
• high dynamics of economic processes creates new types of risks;
• the presence of differentiation of levels of dynamism and intensity of the impact of risks by
region and type of financial transactions.
3. Results and discussion
3.1. Methodical bases of algorithmization for money laundering processes
The method of realization of the system economic analysis principles in the conditions of
counteraction to legalization (laundering) of the proceeds from crime is directed on research processes
formalization, and also statement and the decision of a problem of its functioning. The algorithm is
understood as a finite ordered set of precise rules that describe what actions and in what sequence have
to be performed to achieve the main goal after a finite number of steps or to obtain a solution to the
problem [3].
When analyzing the problem of money laundering, the general block diagram of the research
algorithm can be presented as follows:
1. the essence of risk identification and ways of laundering illegal income;
2. the essence and levels of risk analysis of money laundering: national and micro level;
3. the nature and analysis of the risks of money laundering by financial intelligence entities;
4. indicators of legalization of illegal income, their dynamics, effectiveness of measures to
counteract the legalization of illegally obtained funds.
The general scheme of the algorithm for studying the processes of legalization of proceeds from
crime is shown in Fig.1.
Figure 1: Algorithm for studying the processes of illegal income legalization
Thus, the algorithm of financial investigation and investigation to detect money laundering, means
to establish, record, determine the fact and circumstances of the crime. These include the factors noted
in table 4.
Table 4
Factors for detecting money laundering
Factors Features of manifestation
circumstances of accumulation of time, place, manner and other circumstances of
criminal proceeds the crime
source of illegal origin of funds relocation and use in the legal economy
place of hiding and storage identification of countries involved in money
laundering
identification and identification of legal entities and individuals who are organizers,
persons as well as other persons who participated or may
be involved
nature and extent of damage indicators of the number of financial transactions
and their size
Source [13]
To harmonize Ukrainian legislation in the field of financial monitoring of money laundering with
international standards, the concept of proper customer due diligence has been introduced. This check
involves:
• identification and verification of clients;
• determination of the ultimate beneficial owner of the client;
• setting goals and nature of financial transactions or establishing business relationships;
• monitoring of financial transactions and business relations of the client;
• establishing compliance of client monitoring data with client databases available to the
subject of primary financial monitoring [14];
• establishing data on the client's activities, sources of funds for financial transactions and the
risks of such transactions [15];
• maintaining the relevance of these documents about the client [16].
3.2. Methods for identification money laundering risk subjects
To establish information on the final beneficial owners, Article 17 of the Law on State Registration
of Legal Entities, Individual Entrepreneurs and Public Associations has been supplemented with new
norms. These rules provide for the establishment of the following information about the ultimate
beneficial owners: compliance of the ownership structure in form and content;
• for legal entities of non-residents installation of documents confirming registration
• for individuals, residents and non-residents
• notarized documents certifying the identity of the legal entity.
Data on the ultimate beneficial owners and ownership structure must be kept up to date, and changes
must be notified to the state registrar within 30 days of their occurrence. The procedure for identification
and verification of customers who may be involved in money laundering can be divided to two types:
physically and remotely. Physical way provides for the physical presence of customers and the
availability of copies of the original registration documents. The remote procedure also can be divided
into two types: simplified verification models and full-fledged verification models. Identification and
verification of participants in dubious transactions is possible in several variations. In addition to the
physical presence and a copy of the original documents for non-banking institutions, as well as for
banks, remote identification and customer verification is also available. Full-fledged verification
models are: use of BankID NBU, qualified electronic signature (QES), video broadcasting session, as
well as verification using the resource of state online services "DIYA (ACTION)". When using
simplified models, customer verification involves the use of: data from credit bureaus and BankID
NBU, the presence of QES, reading data from the chip of a biometric document. Intelligent DATA
MINING [17] technologies used in the activities of banks [18] and algorithms for analyzing the
intellectual potential of business entities to determine the risks of financial transactions conducted by
them [10] can be used to verify clients of financial transactions [19].
Remote verification of participants in financial transactions is used in the following cases: for
doubtful financial transactions that are subject to financial monitoring in accordance with the law; on
low-risk financial transactions according to national and international typological studies; in financial
transactions, which allows you to use the physical absence of the client (for example, when concluding
insurance or credit agreements). Thus, remote verification allows you to use the physical absence of the
client when concluding insurance or credit agreements [20-22]. The new requirements for the
establishment of the ultimate beneficial owner, in addition to determining the ownership structure and
registration documents, provide for the establishment of:
• persons who have a decisive influence on the activities of the enterprise, including through
the chain of control or ownership;
• use of data from official documents, information from official and / or other sources;
• establishing measures to verify the accuracy of data on the ultimate beneficial owner ;
• notification to SFMS about discrepancies between the unified state register data and SFMS
data about the ultimate beneficial owner.
The new provision on financial monitoring by banks provides for the use of a list of indicators of
suspicion of financial transactions. These include those shown in table. 5.
Establishing the possibility of using fictitious business entities can be established by identifying the
situations described in table 6.
Reconciliation of registration details is carried out in comparison with the following databases: with
the Unified State Register of Enterprises and Organizations of Ukraine database, data of taxpayers in
the State Fiscal Service of Ukraine; information on the absence of any activity for the specified reporting
period or on availability of data on the movement of significant cash on current accounts. Many legal
and financial intermediaries provide nominal owner services to conceal the ultimate beneficial owners
and generate illicit income.
The system of financial investigations takes into account not only the risks in the field of financial
monitoring, but also compliance risks in the field of business. Compliance - the risk of the business
entity is the probability of losses / sanctions, additional losses or loss of planned income or loss of
reputation due to non-compliance with the law, regulations, market standards, fair competition rules,
corporate ethics, conflicts of interest, and also internal bank documents of the bank.
Table 5
List of indicators of client activity and behavior
Classification List of indicators
feature
Client Lack of data to properly verify, provide incomplete or questionable information
activity Unclear explanations for the nature of the activity
Nervousness for no apparent reason or atypical behavior
Manifestation of unusual interest in the internal system of financial monitoring
Cancellation of a financial transaction upon request for supporting documents or
clarification
Insistence on the urgency of financial aeration and nervousness
Offering various forms of gratitude for conducting a financial transaction
Lack of knowledge of financial transactions on their own account
Excessive justification financial transaction and lack of links with illegal activities
Unable to confirm the customer's phone address and email address
Having a large number of accounts or payment cards that do not meet business
needs
The nature of the financial transaction indicates the presence of another party to an
unknown bank
Absent or unpaid mandatory payments (taxes, utilities, etc.)
The presence of a representative who manages unrelated accounts
Source: created by authors
Table 6
Identification of signs of fictitious business structures
Verification list Fictitious signs
lifespan relatively short life of the entity
Verification of founders registration of the enterprise on fictitious persons (without a
certain place of residence, mentally ill, students, foreigners,
convicts, deceased persons, on the basis of purchased,
stolen or lost documents); registration of a significant
number of business entities with high performance per
person (individual or legal entity)
Name verification the name of the business entity coincides with the name of
the state enterprise; presence of a tax address (existence of a
mass registration address, indication of a non-existent
address or address at which the enterprise cannot be
located)
Checking the signs of absence of signs of statutory activity or carrying out of such
statutory activity activity in the minimum volume; availability of production
facilities, warehouses, vehicles, other movable and
immovable property; activities provided by the classifier of
economic activities; number of employees, income, taxes
and fees paid
Personnel inspection lack of staff to carry out statutory activities; establishment
of beneficial owners; the presence of high performance in
the newly created structures; holding managerial positions
(director / accountant) of the same person
Source [8]
3.3. Risks identification for concealment of beneficiary property
Concealment of beneficiary property is one of the key threats against money laundering. Identifying
the risks of businesses with a non-transparent ownership structure involves identifying the risks of
money laundering.
The ultimate beneficial owner is an individual who, regardless of formal ownership, has the ability
to control and exercise decisive influence over the management and business activities of the business
entity directly or through others. Such control is exercised by exercising the following rights:
• possession or use of assets (or a significant part of them);
• decisive influence on the formation of the management structure and voting results;
• making transactions on business conditions;
• giving mandatory instructions or functions of the governing body;
• influence through direct or indirect ownership of one legal entity independently or jointly
with related parties (individuals and legal entities) share in the property of the joint venture
in the amount of 25% or more of the authorized capital.
At the stage of registration and operation of business entities with a non-transparent form of
ownership, there are such risks:
• fictitious entrepreneurship (according to Ukrainian legislation, fictitious entrepreneurship is
the creation or acquisition of legal entities in order to cover up illegal activities or activities
that are prohibited).
• using of intermediaries of legal and financial services, which in Ukraine include lawyers,
law firms and associations, notaries, auditors, business entities that provide accounting and
legal services, etc. All these intermediaries are required to perform financial monitoring
responsibilities if they are involved in financial transactions for the formation of legal
entities, management and provision of their activities, purchase and sale of corporate rights,
raising funds for the formation, operation or management of business entities [16].
The general scheme of the algorithm for identifying risks of money laundering of business entities
with non-transparent form of ownership is shown in Fig.2.
The concept of the ultimate beneficial owner of a legal entity has come into use in Ukraine together
with the introduction into our legislation of provisions on financial monitoring. The algorithm for
verifying a business entity with an opaque ownership structure consists of the following steps.
• Study of data on individuals
• Study of data ony the legal entity and ownership structure
• Comparison of data on legal entities and individuals with data from the Internet and other
sources of verification.
• Checking legal entities and individuals (owners and managers) for the following data: for
the presence / absence of criminal cases of fraud; business reputation of individuals and
legal entities, the presence of other legal entities in their property, relations with public
figures, etc .; availability of trust agreements / declarations for persons registered in offshore
jurisdictions.
• Analysis of information on the content of statutory activities and the financial condition of
the business entity
• Monitoring the risks of the business entity
• The decision to establish the restoration or abandonment of business relations with business
entities with a non-transparent ownership structure [8].
Figure 2: Algorithm for identifying risks of money laundering of business entities with non-transparent
form of ownership
The main objectives in determining the ultimate beneficial owner are to prevent the illegal use of
legal entities for the purpose of money laundering and terrorist financing, as well as to take measures
to reduce such risks.
In order to establish the ultimate beneficial owner and ownership structure, the subjects of primary
financial monitoring take the following mandatory measures: determine the ownership structure;
analyze and identify persons who own a 25% or more share in the authorized capital of a legal entity
(directly or through related parties); identify individuals who do not own a 25% stake in the share
capital, but have a decisive influence on the activities of the legal entity [11].
One of the main responsibilities of banks, insurance companies, lawyers, accountants is the need to
verify and identify the identity of the ultimate beneficial owner. If during the inspection it is established
that the client is not the ultimate beneficial owner, the financial service providers must establish the
identity of the ultimate beneficial owner. They must require the ownership structure of the legal entity
and documents proving the identity of the ultimate beneficial owner.
If the founder of a legal entity is other legal entities or other legal entities, the inspection should be
carried out until it becomes clear who is an individual who has a significant influence on the activities
of such a company. In case of discrepancies between the official registers and the documents submitted
by the client during the verification of information on the ultimate beneficial owner, it is necessary to
inform the SFMS.
In case of non-submission of information on the ultimate beneficial owner, the Code of
Administrative Offenses provides for the following fines.
• For concealment of information about the ultimate beneficial owner, late or incomplete
submission of documents to the state registrar - from 17 thousand UAH to 51 thousand
UAH, apply to the head of the legal entity or authorized person.
• For violation of the requirements for identifying the affiliation of the ultimate beneficial
owner to politically significant persons, late submission of information on financial
transactions - from 5,100 UAH to 34,000 UAH, apply to officials who carry out financial
monitoring.
Thus, the new rules of financial monitoring, in accordance with the law [8], are intended to improve
the procedure for determining the ultimate beneficial owners with the main goal to eliminate the risks
of money laundering.
4. Conclusion and future work
Algorithmization of the processes of money laundering risks identification is great importance for
the financial monitoring of these risks. The development of financial monitoring procedures involves:
improving the methodological support of the processes of identification and verification of participants
in money laundering processes, the introduction of additional stages of identification and verification
of participants in dubious financial transactions.
The developed algorithms for identifying the risks of legalization of illegal income in the general
case and in part based on the use of data on owners and ownership structure are an auxiliary
methodological tool will allow moving to the digitalization of these processes. The effectiveness of
algorithms for identifying the risks of money laundering can be increased through the using of software
products to automate the processes of identification and verification of participants in financial
transactions and digitalization of processes, which are reflected in typical models of money laundering.
Subjects of primary financial monitoring are obliged to conduct financial investigations in the financial
monitoring system, taking into account: assessment / revaluation of risks, including inherent in its
activities; monitoring risks and documenting their results; keeping up-to-date information on risk
assessment; creation of a risk profile of the subject of primary financial monitoring; documenting the
risks of their clients in such a way as to identify the risks that constitute certain types of clients
(development of risk profile of clients)
Algorithmization of the processes of identification of risks of money laundering is of great
importance for the financial monitoring of these risks. The development of financial monitoring
procedures involves: improving the methodological support of the processes of identification and
verification of participants in money laundering processes, the introduction of additional stages of
identification and verification of participants in dubious financial transactions.
The developed algorithms for identifying the risks of legalization of illegal income in the general
case and in part based on the use of data on owners and ownership structure are an auxiliary
methodological tool will allow to move to the digitalization of these processes. The effectiveness of
algorithms for identifying the risks of money laundering can be increased through the use of software
products to automate the processes of identification and verification of participants in financial
transactions and digitalization of processes, which are reflected in typical models of money laundering.
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