GLOBAL PAYMENTS KNOWLEDGEISO 20022 / SWIFT / SEPA / MT / MX
06 / SANCTIONS FOUNDATIONS18 MIN

Money laundering, terrorist financing, and FATF

The three stages controls are built to disrupt, how terrorist financing differs, and the FATF standards, reporting officers, and intelligence units behind the system.

NOT STARTED

L0 Explain simply

Suppose someone earns a large amount of cash from something they must hide, and they want to spend it openly without anyone asking where it came from. Their problem is that a sudden pile of unexplained money draws attention. So dirty money is usually given a cover story: a path of steps that makes it look as though it arrived honestly, from a job, a business, or an investment. The whole point of anti-money-laundering work is to make that cover story fail. Banks and other firms are asked to know who their customers really are, to watch for behaviour that does not fit, and to tell the authorities when something looks wrong. This is not about proving in the moment that a person is guilty; it is about noticing and reporting the signs, so that investigators can look closer. Think of it as a smoke alarm: its job is to raise the alert reliably, not to put out the fire or decide who lit it.

L1 Core concepts

Money laundering (ML) is usually described in three stages. Placement is getting the illicit funds into the financial system in the first place, the point at which they are most exposed. Layering is moving the money through a series of transactions and accounts to put distance between it and its origin, so the trail is hard to follow. Integration is bringing the now disguised money back into the open economy as apparently legitimate wealth. Understanding these stages matters because each one offers controls a chance to notice. Knowing a customer well makes suspicious placement stand out. Monitoring behaviour is aimed at spotting the rapid, fragmented movement typical of layering. And due diligence on large or unusual inflows can question integration. This topic explains the stages so that the reasons behind the controls are clear; it does not describe how to carry laundering out, because the purpose here is to detect and disrupt it.

L2 Practitioner view

Terrorist financing (TF) sits next to money laundering but works differently, and the difference shapes the controls. Money laundering starts with criminal proceeds and tries to hide where they came from. Terrorist financing is about funding activity, and the money can come from legitimate sources, such as donations or a genuine salary, as well as criminal ones. The sums involved can be small, which means threshold-based checks alone may miss them. So the emphasis shifts from tracing the origin of large dirty sums toward understanding the destination and purpose of funds, and toward screening parties against sanctions and terrorism lists. Both money laundering and terrorist financing are addressed by the same broad toolkit, knowing the customer, monitoring behaviour, and reporting suspicion, but a control tuned only to spot large, layered flows would be poorly suited to catching a small transfer to fund harm. Good programmes account for both risks rather than assuming one shape of wrongdoing.

L3 Technical details

The global rulebook comes from FATF (the Financial Action Task Force), an intergovernmental body that sets standards against money laundering and terrorist financing. Its standards are expressed as the 40 Recommendations, which cover measures such as customer due diligence, record keeping, beneficial ownership transparency, and suspicious transaction reporting. FATF does not police individual banks; it assesses countries. Through mutual evaluations, teams review how well a country's laws and its firms actually meet the standards, not just on paper but in effect. Where a country falls short, FATF can place it on public lists, informally called the grey list for jurisdictions under increased monitoring and the black list for the most serious cases. Being listed pressures a country to improve, because banks elsewhere apply extra caution to dealings with listed jurisdictions. In this way FATF turns a shared set of expectations into real consequences, aligning national laws so that criminals cannot simply move to whichever country has the weakest defences.

L4 Standards & sources

Inside a firm, the FATF (Financial Action Task Force) standards land as concrete roles. When a staff member notices something that does not add up, they raise it internally rather than confront the customer. Those concerns reach the money laundering reporting officer (MLRO), the senior person accountable for the programme, who decides whether the firm should file a suspicious activity report (SAR). The SAR goes to the national financial intelligence unit (FIU), the agency that receives such reports, analyzes them, and passes intelligence to law enforcement. Two points are worth holding onto. First, the obligation is to report suspicion, not to prove a crime; the firm raises the flag and the FIU and investigators take it from there. Second, tipping off, warning a customer that they are being reported, is itself prohibited, because it would let funds and evidence disappear. A caution for readers: the exact names of these roles, reports, and thresholds vary by country, and the description here follows the common pattern the FATF Recommendations promote rather than any single national law.

Sources & standards1
  1. Official requirement

    The FATF Recommendations: International Standards on Combating Money Laundering and the Financing of Terrorism & ProliferationFinancial Action Task Force · FATF 40 Recommendations, customer due diligence and suspicious transaction reporting

    The global standards countries implement against money laundering, terrorist financing, and proliferation financing, including targeted financial sanctions and payment transparency under Recommendation 16. · Checked 2026-07-12

    Adopted in 2012 and updated regularly since; the June 2025 FATF plenary agreed revisions to Recommendation 16 on payment transparency. Consult the live consolidated text for the current wording.

Sources for this topic2
  1. Official requirement

    The FATF Recommendations: International Standards on Combating Money Laundering and the Financing of Terrorism & ProliferationFinancial Action Task Force · FATF 40 Recommendations, customer due diligence and suspicious transaction reporting

    The global standards countries implement against money laundering, terrorist financing, and proliferation financing, including targeted financial sanctions and payment transparency under Recommendation 16. · Checked 2026-07-12

    Adopted in 2012 and updated regularly since; the June 2025 FATF plenary agreed revisions to Recommendation 16 on payment transparency. Consult the live consolidated text for the current wording.

  2. Simplified educational illustration

    Payments Signal editorial teaching modelsPayments Signal

    This site's own simplified teaching models. · Checked 2026-07-12

    What this simplifies: The smoke-alarm framing and the compressed three-stage story are deliberately high level and defensive; they describe why controls exist and how detection works, not any method of committing the offence.

    Used wherever diagrams, scenarios, figures, or example values are didactic constructions rather than sourced facts; every such use carries a simplifications disclosure. All people, companies, banks, and list entries in examples are fictional.

Deepest material on this page: L4 Standards & sources. Where a topic stops short of implementation depth, that is a deliberate coverage decision, not an oversight — see coverage.