

Case 2: Risk Analysis and Prevention Strategies for New Intermediary Arbitrage Money Laundering Models
I. Operational Mechanism of New Money Laundering Models
Criminals set up shell company structures and lure recruits with high service fees ranging from 7% to 15%, using them as

2. Identification of Core Risk Points
Doubtful Legitimacy of Fund Sources:Due to the layered transactions through intermediaries, the initial source of funds cannot be traced back through direct transaction links. Neither the clients nor the intermediaries can provide legitimate documentation for the source of funds, which may originate from illegal activities such as drug trafficking, telecom fraud, or corruption.
Concealment of Actual Beneficial Owner's Identity:The behind-the-scenes
3. Optimization of Anti-Money Laundering Strategies
Strengthening the Identification of Abnormal Transaction Structures: Review personnel should focus on transactions involving three or more parties, especially those "side business" transactions that have obvious arbitrage potential and do not align with the customer's regular business background. When transactions exhibit characteristics such as "asymmetrical costs at both ends of the fund flow with no reasonable commercial purpose in intermediary links," enhanced review processes should be immediately initiated.
Upgrading the Identity Verification Mechanism:Relying solely on customer self-reports or basic identity verification is no longer adequate to combat new money laundering methods; it is necessary to establish a "multi-dimensional cross-verification" system:
Service Locations
-Part A, Ground Floor,
80s, Tung Kwun Wan Road, Kuala Lumpur
Hong Kong Special Administrative Region

