This is the second in a series of articles discussing the internet tools I use as an anti-money laundering analyst. You can find the complete toolbox here, and my previous article on tools for researching companies here.
Banks play an important role in the world of financial crime. On the one hand, bank compliance units spend countless hours and billions of dollars searching for and reporting dubious transactions to assist law enforcement in stopping crime. On the other hand, banks are sometimes knowing conspirators in that crime: Danske Bank’s Estonian subsidiary, for example, appears to have funneled billions in suspicious Russian funds into the rest of the world. Theirs was not simply a passive ignorance — the Russian central bank itself warned Danske’s head office about the laundering operation — but the inexplicably high profits from the tiny satellite branch were too much to pass up.
For compliance analysts and other researchers, understanding the banking landscape is crucial for investigating financial crime. Tracing correspondent banking flows, checking counterparty banks’ reputations, and accessing credit card data can be the key to catching money laundering or other illicit activity.
I’ve put together a list of a few tools I’ve found useful in my work. The relevance of some of these tools will vary based on the user’s position and goals, but I hope everyone will find something to add to their arsenal. Let me know what you think, especially if you have a site for me to add!
Negative News String
A Google search string that covers all the basics: if the entity name has any obvious/reported links to financial crimes, including bribery, drug trafficking, fraud, etc., this will return that information.
This a very cool tool for finding information about credit and debit cards. The first 8 numbers on payment cards are known as the IIN or BIN, and they contain information about the card issuer and the card itself. Drop those numbers into this site, and it will tell you a) what financial institution issued the card (e.g. Bank of America), b) the country the card was issued in, c) what network it belongs to (e.g. Visa or Mastercard), d) whether it is a credit or debit card, e) whether or not it is a prepaid card (surprisingly important for money laundering research), and a couple other good bits of data.
SWIFT Code Lookup
SWIFT is a messaging system used to make international wire transfers. Each bank has it’s own “handle” in that messaging system, which is typically referred to as a BIC (Bank Identification Code). Knowing a BIC can be important for tracing where wires were sent to/from or where they passed through.
Each BIC has the same structure: a 4-letter bank code, a 2-letter country code, a 2-character location code, and possibly a 2–3-character branch code. For example, CHASUS31HPQ: CHAS is for JP Morgan Chase; US is the country; 31 is the location, which in this case is NYC; and HPQ is the branch.
I’ve tried a number of different BIC lookup sites, and this is the best one. Others either a) return false/unclear results, b) don’t allow you to search partial codes, or c) don’t have a user-friendly interface.
Country Codes List
The 2-letter country code above follows a standardized protocol that isn’t always intuitive. Cambodia for example, is KH, and Algeria is DZ. For that reason, I like to keep this list handy.
Routing Number Search
Like SWIFT BICs, routing numbers are bank-specific codes combined with account numbers to help process transactions, but they are used for different types of payments. I’ve not personally had occasion to use routing numbers in investigations, but I keep this nearby just in case.
Like many other financial investigators, I’m not from a banking/business/finance/etc. background. I often need to define terms or understand more about how certain banking processes work. Investopedia has rarely let me down — it has many entries on a wide variety of topics, and they’re accessible without sounding childish. Just replace the Xs with your term and search away!
Oanda Currency Converter
There are many, many currency converters out there, but I like this one because you can change the conversion date. For example, you can find what a Euro payment in October 2013 equalled in USD.
Currency List Wiki
If you work with international payments, it can be helpful to see currency codes and find out where currencies are used. This table also links to pages for individual currencies, which have images of coins/banknotes and other info that could be useful in investigations.
List of Banks Wiki
This is a landing page with links to several lists of banks (all banks in the world, largest banks by assets, banks by continent, etc.). Bank websites are not very effective for finding business information like assets, branches, subsidiaries, etc., as most are oriented toward online banking and advertising. Wiki pages are a good resource for finding that research information at a glance.
Another nice way to find bank information, as long as the bank is in the US or is otherwise regulated by the FDIC. In addition to regular “demographic” information, you can find the bank’s regulator, the location of its branches, and other useful information. I use this over Wikipedia whenever possible, especially if I need to list it as a source.
Know Your Country
A helpful place to catch up on country-specific banking risks. The site publishes country reports that include information on sanctions, inclusion on regulatory blacklists, bribery risk, the country’s economy, and other helpful information.
The Financial Action Task Force is an international organization that handles money laundering and illicit finance issues. It serves as a forum for multilateral collaboration and produces policy recommendations and other related documents. From an investigation standpoint, relevant documents include “mutual evaluation” reports, which are assessments of countries’ money laundering regimes by other member states, and typology reports, which are research/explanatory reports focused on certain aspects of financial crime.
FFIEC Manual String
The FFIEC (Federal Financial Institutions Examination Council) manual is the AML analyst’s bible. It’s the document that sets out what regulators look for in tests of financial institutions’ compliance practices, but it also includes good information about red flags associated with different schemes and banking practices. As with any bureaucratic document, it’s really long (there are like 20 appendices), so I usually search it with a Google string.
OFAC Sanctions Lookup
Sanctions are all over the news these days, and policy is always changing. The US sanctions regime is likely the most consequential and thorough in the world, and it is administered by the Office of Foreign Asset Control (OFAC) under the Treasury Department. They have a nice webform that allows you to search the sanctions list for individuals or companies and find directory information about them (e.g. nationality, address, etc.) if available.
FinCEN Enforcement Actions
The Financial Crimes Enforcement Network (FinCEN) is the US financial intelligence unit, and it is a hub for illicit finance information. This link is to the newsfeed of the Network’s “enforcement actions,” which are essentially rulings against financial institutions that have engaged in illegal activity. This is useful for researching individual institutions, but it is also a valuable source for keeping up on financial crimes trends. Other agencies issue enforcement actions or similar rulings, which can be found via Google. Other notable FinCEN resources: this Geographical Targeting Order (GTO), which requires title agencies to report on cash real estate purchases in certain areas (Miami, San Antonio, NYC, Hawaii, western California); and the 311 Special Measures list, which includes entities of “special money laundering concern.”