A Guide to AML Investigation Techniques: Tips, Requirements and OSINT

Effective AML investigations are more important than ever. Illicit actors engaged in money laundering activities are growing more sophisticated, harnessing technological advancements to avoid detection by current AML measures. The UK’s National Crime Agency now estimates that money laundering costs the UK more than $100 billion every year.

Investigators in financial institutions (FIs) have struggled to keep pace with these innovations and require a more effective approach to financial crime risk management. They are now moving away from technical compliance and ‘box-ticking’ methods, towards the proactive detection and prevention of financial crime.

Adopting a more effectiveness-focused approach means AML investigations are more in-depth. This helps reduce the probability of facing damaging consequences of money laundering, such as fines and reputational damage. It also means FIs can produce better intelligence for law enforcement.

In this guide, we will outline why open source intelligence (OSINT) should play a key role in improving the quality of AML intelligence and investigations activities. 

Suggested reading: You can learn more about how OSINT is improving best practices in a range of investigations in our free eBook — The OSINT Handbook

Regulations, requirements and open source intelligence

Theoretically, AML strategies, policies and processes should be risk-prioritised, with deeper investigation conducted where red flags are present. However, identifying high-risk clients or transactions is easier said than done. Thorough due diligence can also be hard for banks to achieve, with high volumes of transactions limiting efficiency.

Perhaps due to these challenges, a substantial proportion of fines for AML transgressions have been due to intelligence failures.

The reality is that many existing AML workflows fail to scratch the surface of available — and useful — data on subjects of interest.

As a result of these shortcomings, regulators and FIs alike have begun to consider OSINT as an effective tool for augmenting existing processes. OSINT describes the process of extracting intelligence from publicly available and licensable data. Regulators have also begun to include OSINT in their specifications, for example:

• The FCA’s Financial Crime Guide encourages the use of “open source internet checks to supplement commercially available databases.”
• The European Banking Authority (EBA) encourages enhanced due diligence (EDD) measures to include “carry out open source or adverse media searches” on an ongoing basis.

OSINT encourages a more nuanced and holistic approach to the AML investigation process, which goes further than superficial checks.

OSINT and AML investigations

The core purpose of OSINT is to extract insights from publicly available information. This information is available in numerous OSINT sources.

Chief among the key challenges of conducting effective DD and EDD is understanding a client’s links, networks and business operations. Using OSINT, investigators can unlock insights into individuals and organisations that aren’t present in other sources. This aids in understanding networks and increasing visibility of potential criminal activity and illicit sources of funds.

The role of open source data

High-quality AML investigations often need to go beyond superficial checks to uncover key risks.

With OSINT, researchers can uncover networks, connections and potential red flags to illuminate hidden insights. By extending searches into leaked information (e.g. the Pandora Papers), corporate records, grey literature, social media and the dark web, investigators can identify and map risks more effectively. This allows investigators to understand suspicious activity in depth and submit high-quality Suspicious Activity Reports (SARs) to law enforcement.

OSINT is useful within both proactive and reactive AML investigations:

• Reactive investigations with OSINT: Reactive investigations help researchers understand the context surrounding an alert generated by screening and monitoring systems. For example, this alert may come from a suspicious transaction or customer onboarding processes. Here, OSINT allows researchers to confirm whether suspicious activity is taking place after a trigger event and enables further research if necessary.
• Proactive investigations with OSINT: OSINT can be used proactively to conduct thematic assessments into high-risk industries, jurisdictions or business activities. Identified entities can then be screened proactively against customer data to identify previously unknown risks. This strengthens and supplements existing processes.

Going beyond compliance with OSINT

OSINT is a vital piece of the AML puzzle. By integrating OSINT into the AML workflow, businesses can go beyond “box-ticking” compliance and build more sophisticated AML and AFC processes.

With that said, not all OSINT methods offer the same insights. Cutting-edge OSINT tools are crucial in unlocking the value that open source data can add to AML investigations.  

With these tools, financial institutions can progress towards a more proactive, intelligence-led AML model that provides them with: 

• Resilience: Building resilience against the abuse of the financial system by illicit actors is essential as governments and regulators ramp up the pressure on FIs to improve AML processes.
• Efficiency: To allow for completion of investigations within the necessary timeframes, AML processes should be efficient. Automated tools can handle mundane, repetitive tasks, so human teams can focus on nuanced analysis, where they are most valuable. 

Suggested reading: Learn more about the role technology plays in AML by reading our deep dive on AML technology trends.

Comprehensive AML investigations with Videris

Conducting more effective AML investigations requires investigators to use all of the information available to them. That means leveraging the power of OSINT effectively.

One AML software solution that empowers better use of OSINT within critical anti-financial crime investigations is Videris. This powerful, all-in-one intelligence platform supports the AML workflow, unlocking new opportunities to drive AML efficiency and effectiveness.

Videris contains a wide range of functionality designed to make OSINT investigations as effective as possible. This includes: 

• Videris Search: Don’t waste time switching between platforms to access different sources. Videris allows users to search all relevant sources at once and intelligently prioritises results.
• Corporate Network Mapping: Understand corporate networks at speed using intuitive network mapping. Discover hidden links, identify beneficial owners and monitor activity in high-risk markets or jurisdictions.
• Cross-Matching and Entity Extraction: Identify connections that are hard to spot. Videris uses intelligent automation (IA) to perform the complex task of extracting named entities and cross-matching results. 
• Secure Browsing and Flexible Deployment: The Videris platform reduces the risk of identity breaches by enabling secure, traceless browsing. 

See for yourself how Videris can augment your approach to AML investigations and help you produce better outcomes: book a demo with one of our experts today.