Financial crime doesn’t knock on the door; it slips through cracks in governance.

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The Financial Intelligence Unit (FIU) has published an analysis of Trust and Corporate Service Providers (TCSP’s) – related threats and vulnerabilities. For boards, this isn’t just a compliance issue, it’s a reputational and strategic risk.

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Key Insights (Typologies)

• Third-Party intermediaries used to obscure settlor contributions

• Suspected corruption linked to a foundation

• Dual nationality used to conceal high-risk or sanctioned jurisdiction links

• Falsified documentation in a high-value cross-border share transaction

 
Key Insights (Red Flags)

• Unusual payment routing through third parties without clear justification.

• Requests for documentation contradicting verified information.

• Connections to politically exposed persons (PEPs) or high-risk jurisdictions.

• Evasion or incomplete disclosure of nationality or passport history.

• Irregularities in identification documents or share certificates.

• Pressure to complete high-value transactions quickly or bypass controls.

 
Risk Implications & Controls

• Apply enhanced due diligence (EDD) for high-risk jurisdictions and sectors, and when required, for settlors and any third‑party contributors.

• Scrutinise the rationale for intermediary involvement and assess the AML governance of any intermediary involved.

• Ensure robust verification and scrutiny of source of funds and wealth.

• Require full disclosure of all nationalities.

• Continual adverse media and open-source intelligence screening, including name variations.

• Transaction monitoring should flag all non‑settlor payment channels for review.

 
Next Steps

• Integrate the insights from the strategic analysis into the business’s compliance framework, including;

• Staff training,

• Transaction monitoring protocols; and

• The drafting of Suspicious Activity Reports (SARs).

 
How Aspida can help
Resolver by Aspida is used for board‑ready MI, control mapping, continuous risk assessments, and audit‑ready oversight.
Our highly experienced MLROs, MLCOs and compliance specialists deliver independent internal audit, complex due diligence reviews, policy and control framework development, and bespoke AML/CFT/CPF and sanctions training.

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Take action:
Boards that act now will not only meet regulatory expectations, but they’ll also protect their organisations from financial crime and reputational damage.

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Get in touch with the specialists at Aspida to benchmark your governance, controls, and technology against the latest risks