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PAY-047 Payments & Banking

Could one person operate several bank accounts?

Yes. One person may legitimately or unlawfully operate several bank accounts.

Avoid this assumption: Separate account numbers necessarily mean separate users.

A person may hold current, savings, business, joint or foreign-currency accounts with one or several institutions.

They may also be authorised to operate accounts belonging to a company, family member, client or organisation.

In criminal activity, one person may control several mule, nominee or compromised accounts while avoiding appearing as the named holder.

Common control may be indicated by shared devices, IP addresses, phone numbers, email addresses, authentication methods, beneficiaries, transaction patterns or rapid transfers between accounts.

Communications may show instructions or coordination. Device evidence may show several banking applications, saved credentials or active sessions.

But a shared identifier is not conclusive on its own. A household, business network, accountant or shared device can create legitimate overlap.

The investigation should separate legal ownership, authorised access and actual control.

Ask each bank for account-opening records, authorised users, linked devices, login history, contact details and relevant transactions.

Map transfers between the accounts and identify whether they form a functional group.

Look for common timing, repeated destinations, circular transfers or coordinated cash withdrawals.

Do not assume that the person whose device accessed several accounts owned the funds. Equally, do not ignore evidence that one person directed activity across accounts held in other names.

Where the structure is complex, specialist financial investigation support may be required.

When reporting, describe the evidence linking the accounts and state whether common control is established, supported or merely suspected.

Operational takeaway

Test whether several accounts share a common controller by comparing account, device, access, communication and transaction evidence rather than relying on account names alone.


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