Phoenix Compliance Essentials #21
Today’s focus: rebound accounts, understanding a circumvention scheme used in money laundering networks.
➡️ Definition
A rebound account (also referred to as a transit account) is a bank or payment account used as an intermediary to conceal the origin of funds or circumvent certain control measures and international sanctions.
In practice, funds pass through one or more successive accounts, making it possible to fragment transaction flows and reduce their traceability.
Any account capable of receiving funds may be used as a rebound account.
➡️ What the ACPR’s findings reveal
The report on preventing the use of rebound accounts for laundering the proceeds of scams and other fraud highlights that:
👉 Nearly 70% of rebound accounts in France are opened less than one year before they are used, reflecting their opportunistic nature.
👉 Digitalisation and instant payments accelerate the movement of funds and facilitate their use.
👉 Funds are transferred through several countries in most cases, making detection more complex.
👉 Rebound accounts are often located in European countries, giving them an appearance of legitimacy.
➡️ Commonly observed schemes
Criminal networks rely in particular on:
👉 Shell companies with fictitious or opaque business activities
👉 Accounts opened in jurisdictions with no apparent connection to the account holder’s profile
👉 Stolen or forged identities
👉 The acquisition of existing companies used as intermediary vehicles
👉 Money mules who temporarily make their accounts available
➡️ Point of attention
Criminal networks are now incorporating advanced technologies to circumvent control measures.
👉 Generative artificial intelligence and deepfakes can be used to forge identities or undermine certain identity verification procedures.
➡️ Good practices
To address these schemes, institutions should:
👉 Strengthen customer due diligence (KYC)
👉 Verify the consistency between the customer’s profile and transaction flows
👉 Ensure full traceability of transactions
👉 Obtain reliable and consistent supporting documentation
👉 Detect unusual transaction patterns
In practice, rebound accounts illustrate how money laundering schemes combine speed, fragmented transaction flows and the circumvention of control measures.
