FATF reference

Typology playbooks

4 playbooks — these power the agent's search_typology_playbook MCP tool.

FATF-STR-001

Structuring / smurfing

FATF

Splitting cash deposits below reporting threshold across branches or days to avoid CTR/SAR aggregation.

Red flags

Deposits clustered just under reporting threshold
Multi-branch dispersal in short window
Round-number amounts below threshold
No legitimate source-of-funds rationale

FATF Recommendation 10 · Guidance on CDD and indicators of structuring

SAR narrative template

Subject {entity} conducted {n} cash deposits of £{range} across {branches} branches within {window}, each falling below the £10,000 CTR threshold. Pattern consistent with structuring typology.

FATF-LAY-003

Layering via shell vehicles

FATF

Rapid movement of funds through multiple newly incorporated entities with no operational substance.

Red flags

Newly incorporated entity
No trading history
Generic business description
Multi-jurisdiction ownership

FATF Typologies Report 2023 · Shell company misuse

FATF-SMU-002

Smurfing into concentration account

FATF

Many originators depositing into a single beneficiary account to obscure source of funds.

Red flags

Many distinct small originators
Single beneficiary
No commercial relationship between originators and beneficiary

FATF Typologies · Cash-intensive businesses

FATF-SAN-004

Sanctions nexus

FATF

Counterparty or beneficial owner partially matches an OFAC/EU/UN list with sufficient confidence to escalate.

Red flags

Name + DOB partial match
Shared jurisdiction with sanctioned entity
Routing pattern through sanctioned corridor

FATF Recommendation 6 · Targeted financial sanctions