Glossary

The vocabulary of AML, from A to Z.

Every term you meet in a policy, an audit report or a supervisory letter — explained in two lines, with a link to go further.

A–Z70 terms

A

Adverse media Sanctions & PEPs
Negative news about a customer or beneficial owner that may indicate involvement in crime or a higher risk. Part of screening, to be assessed rather than counted.
AML/CFT Basics
Anti-money laundering and countering the financing of terrorism — the umbrella term for the whole framework. Often extended to AML/CFT/CPF to include proliferation.
AMLA Institutions & law
The EU Anti-Money Laundering Authority, based in Frankfurt. It coordinates national supervisors and FIUs and will directly supervise selected high-risk institutions from 2028. Learn more →
AMLD6 Institutions & law
Directive (EU) 2024/1640, which organises national supervisors, FIUs and beneficial ownership registers. Largely to be transposed by 10 July 2027. Learn more →
AMLR Institutions & law
Regulation (EU) 2024/1624, the EU single AML/CFT rulebook. Directly applicable across the Union from 10 July 2027. Learn more →
Asset freeze Sanctions & PEPs
A prohibition on moving, transferring, altering or using the funds and economic resources of a designated person.
Asset-side due diligence Investment funds
AML/CFT checks on what the fund invests in and who it deals with — targets, sellers, co-investors, counterparties. A key expectation for alternative fund managers. Learn more →

B

Beneficial owner (UBO) Ownership
The natural person or persons who ultimately own or control a customer, or on whose behalf a transaction is carried out. Always a human being, never a company. Learn more →
Beneficial ownership register Ownership
A central register of beneficial owners of companies and trusts — in Luxembourg, the RBE. Since a 2022 ruling of the EU Court of Justice, access is no longer open to the general public. Learn more →
Business-wide risk assessment Basics
An obliged entity's documented assessment of the money-laundering and terrorist-financing risks it is exposed to — customers, products, geographies, distribution channels — kept up to date and approved by management. Learn more →

C

Correspondent relationship Due diligence
One institution providing services to another — typically a bank clearing payments for a foreign bank. Requires specific due diligence on the respondent and its controls. Learn more →
CSSF Institutions & law
The Luxembourg financial supervisor — banks, investment firms, payment institutions, fund managers and investment funds.
Cuckoo smurfing Typologies
Criminals deposit cash into the account of an unsuspecting person who is expecting a legitimate international transfer — and take over the payment.
Customer due diligence (CDD) Due diligence
Identifying and verifying the customer and its beneficial owners, understanding the purpose and intended nature of the relationship, and monitoring it throughout its life. Learn more →
Customer risk rating Due diligence
The risk level assigned to each customer from a set of factors. It drives the depth of due diligence and the frequency of reviews.

E

Egmont Group Institutions & law
The international network of financial intelligence units, created in 1995, through which FIUs exchange information securely.
Enhanced due diligence (EDD) Due diligence
Additional measures for higher-risk situations: more information on the customer and beneficial owners, source of funds and wealth, senior-management approval and closer monitoring.

F

False positive Sanctions & PEPs
A screening or monitoring alert that, once reviewed, turns out not to concern the customer. Every closure needs a documented rationale.
FATF (GAFI) Institutions & law
The Financial Action Task Force, the intergovernmental standard-setter created by the G7 in 1989. Its 40 Recommendations are the global AML/CFT standard. Learn more →
Financial intelligence unit (FIU) Reporting & controls
The national centre that receives and analyses suspicious transaction reports and disseminates intelligence — in Luxembourg, the CRF. Learn more →
Front company Typologies
A real business — restaurant, car wash, trading company — that mixes illicit proceeds with genuine revenue.

G

Grey list Institutions & law
The FATF list of jurisdictions under increased monitoring. The 'black list' covers high-risk jurisdictions subject to a call for action. Learn more →

H

Hawala Typologies
An informal value-transfer system: brokers pay out in one country against funds received in another and settle their balances later — value moves, money doesn't. Learn more →

I

Integration Basics
The final stage: the funds return to the legitimate economy as apparently clean wealth — property, investments, business income. Learn more →
Investor due diligence Investment funds
CDD on the investors who subscribe to a fund. Often performed by the registrar and transfer agent on behalf of the fund or its manager, who remain responsible. Learn more →

K

KYC (Know Your Customer) Due diligence
Knowing who the customer is, what they do and why they come to you. Commonly used as shorthand for customer due diligence. Learn more →

L

Layering Basics
The second stage: moving funds through successive transactions, accounts, companies and jurisdictions to break the audit trail. Learn more →
Loan-back Typologies
Lending your own illicit money to yourself through an offshore entity, so that it comes back looking like a loan.

M

Mirror trading Typologies
Buying securities in one currency and selling the same securities in another through related parties, to move value across borders.
Mixer (tumbler) Crypto
A service that pools and redistributes crypto-assets to break their traceability. Exposure to mixers is a strong risk indicator.
Money laundering Basics
Disguising the criminal origin of proceeds so that they appear legitimate. Usually described in three stages: placement, layering and integration. Learn more →
Money mule Typologies
A person who lets their account be used to receive and pass on illicit funds — sometimes knowingly, often recruited through job or romance scams.
Mutual evaluation Institutions & law
The peer review of a country's AML/CFT system, assessing both technical compliance with the 40 Recommendations and effectiveness in practice.

N

National risk assessment (NRA) Basics
A country's assessment of the threats and vulnerabilities it faces. Firms are expected to reflect its conclusions in their own risk assessments.
Nominee Ownership
A person who holds shares or a directorship on behalf of someone else. The arrangement must be disclosed and the person behind it identified.
Nominee in distribution Investment funds
A distributor holding fund units in its own name on behalf of underlying investors. Requires due diligence on the nominee and on the controls it applies to its clients.

O

Obliged entity Basics
A business subject to AML/CFT obligations: banks, payment and e-money institutions, investment firms, fund managers, insurers, crypto-asset service providers, and professions such as notaries, accountants, lawyers (in certain activities) and real-estate agents.
Ongoing monitoring Due diligence
Scrutinising transactions throughout the relationship and keeping customer information current, to check that activity stays consistent with what you know.

P

Periodic review Due diligence
A scheduled refresh of the customer file, at a frequency driven by risk — and earlier whenever a trigger event occurs.
Placement Basics
The first stage of laundering: getting criminal proceeds, often cash, into the financial system — deposits, cash-intensive businesses, currency exchange, purchase of assets. Learn more →
Politically exposed person (PEP) Sanctions & PEPs
Someone entrusted with a prominent public function, plus their family members and close associates. Not a suspect — a higher-risk profile that requires enhanced due diligence. Learn more →
Predicate offence Basics
The underlying crime that generates the proceeds being laundered — fraud, corruption, drug trafficking, tax crimes and many others. Without a predicate offence there is nothing to launder. Learn more →
Proliferation financing (PF) Basics
Financing the development, acquisition or transfer of weapons of mass destruction and their delivery systems. Countered mainly through targeted financial sanctions. Learn more →

R

Real-estate laundering Typologies
Buying property with illicit funds, often through companies or trusts, with cash, inflated or deflated valuations, or quick resales.
Record keeping Reporting & controls
Keeping due-diligence documents and transaction records, generally for at least five years after the end of the relationship, retrievable quickly by the authorities. Learn more →
Red flag Reporting & controls
An indicator that warrants a closer look. One red flag is a question, not a conclusion. Learn more →
Registrar and transfer agent Investment funds
The entity that keeps a fund's register of investors and processes subscriptions and redemptions — usually the front line of investor due diligence.
Reliance on third parties Due diligence
Using customer due diligence performed by another regulated entity. Allowed under conditions — but the relying entity keeps full responsibility. Learn more →
Remote onboarding Due diligence
Onboarding a customer without physical presence. Acceptable when identity is verified through reliable means such as qualified electronic identification.
Risk-based approach (RBA) Basics
Applying measures in proportion to the risk identified: enhanced where risk is higher, simplified where it is demonstrably lower. The organising principle of the FATF standards. Learn more →
RR and RC (Luxembourg) Reporting & controls
In Luxembourg, the RR is the member of senior management responsible for AML/CFT compliance; the RC is the compliance officer in charge of controlling it day to day.

S

Sanctions screening Sanctions & PEPs
Checking customers, beneficial owners, counterparties and payments against applicable sanctions lists — UN, EU, national and, where relevant, others. Learn more →
Senior managing official Ownership
The person recorded when no beneficial owner can be identified through ownership or control — a fallback, which must be documented, not a shortcut.
Shell bank Due diligence
A bank with no physical presence where it is incorporated and licensed, and not part of a regulated group. Correspondent relationships with shell banks are prohibited. Learn more →
Shell company Typologies
A company without significant operations or assets. Often legitimate, but a classic tool to hide ownership and move funds.
Simplified due diligence (SDD) Due diligence
Reduced measures allowed where the risk is assessed as low. It lightens CDD; it never removes it, and it stops as soon as suspicion appears.
Source of funds (SoF) Due diligence
Where the money used in a specific transaction or subscription comes from — which account, and how it got there.
Source of wealth (SoW) Due diligence
How the customer built their overall wealth — employment, sale of a business, inheritance, investments. Checked in higher-risk cases, notably for PEPs.
Structuring (smurfing) Typologies
Splitting cash deposits or transfers into amounts below identification or reporting thresholds, often using several people — the 'smurfs'.
Suspicious transaction report (STR/SAR) Reporting & controls
A report to the financial intelligence unit when you know, suspect or have reasonable grounds to suspect that funds are the proceeds of crime or linked to terrorist financing. Learn more →

T

Targeted financial sanctions Sanctions & PEPs
Asset freezes and the prohibition to make funds available to designated persons and entities. They must be applied without delay. Learn more →
Terrorist financing (TF) Basics
Providing or collecting funds, by any means, knowing or intending that they will be used for terrorist acts or by terrorists. The money can be perfectly clean — what matters is where it goes. Learn more →
Tipping-off Reporting & controls
Disclosing to the customer, or to anyone else, that a report has been or may be filed, or that an analysis is under way. Prohibited. Learn more →
Trade-based money laundering (TBML) Typologies
Moving value through trade: over- or under-invoicing, phantom shipments, multiple invoices for the same goods, misdescribed merchandise.
Transaction monitoring Reporting & controls
The rules, scenarios and systems that detect unusual patterns for investigation. Its value lies in coverage, calibration and the quality of the reviews. Learn more →
Travel rule Crypto
Originator and beneficiary information must travel with transfers — including crypto-asset transfers, under the EU rules applicable since 30 December 2024. Learn more →

V

VASP / CASP Crypto
Virtual asset service provider (FATF term) or crypto-asset service provider (EU term): exchanges, custodians, brokers and similar, all subject to AML/CFT rules. Learn more →

W

Wolfsberg Group Institutions & law
An association of global banks that publishes AML guidance and standard tools, such as the correspondent banking questionnaire.