How I Caught Layering in Mobile Banking: A Deep Dive into AML Rule Engines
Photo by Areza Pahlevi on Unsplash Imagine being on audit, staring at a sea of transactions, and realizing your AML rule engine missed a massive layering scheme. This happened to me. The numbers were staggering: BDT 10 million laundered through bKash, all under the BDT 100,000 threshold. I had to act fast. The Hidden Problem Standard AML approaches focus on flagging individual transactions, not the bigger picture. Layering, a technique used to disguise the origin of illicit funds, slips through the cracks. In Bangladesh, this is particularly problematic due to the prevalence of mobile financial services (MFS) like bKash and Nagad. The BFIU guidelines emphasize monitoring transactions above the BDT 100,000 threshold, but layering often involves smaller, frequent transactions. Technical Breakdown & Logic Flow To catch layering, you need to analyze transaction patterns over time. This involves identifying velocity (the frequency of transactions) and aggregation (the total value...