What is a pass-through account?¶

A pass-through account is an account used mainly or significantly to receive funds and move them onward, often with little value retained.

Avoid the dangerous assumption¶

The dangerous assumption is that any account with matching incoming and outgoing payments is automatically a criminal pass-through account.

The account may be used to create distance between the source and final recipient, aggregate several payments or divide money across multiple destinations.

It may be a bank account, payment account, wallet, business account or other value-holding service.

Relevant indicators can include rapid onward transfers, repeated similar amounts, low retained balance, numerous unrelated senders and common destination accounts.

But legitimate businesses, agents, payroll services, client accounts, marketplaces and family arrangements can produce similar patterns.

The investigation should establish the account’s genuine purpose, normal activity, authorised users and practical controller. It should also identify whether the same destinations recur across unrelated incoming payments.

Map incoming and outgoing transactions by amount, time, reference, source and destination.

Do not assume a perfect one-to-one match.

Funds may be mixed, split, combined, reduced by fees or withdrawn in cash.

Account-access, device and communication records may show whether the holder or another person directed the movement.

Look for instructions, retained commission, account rental, credential sharing or attempts to conceal the route.

When reporting, distinguish the observed pass-through pattern from the conclusion that the account was knowingly used for criminal funds.

Operational takeaway¶

Identify the account’s normal purpose and map how funds entered, mixed and left before concluding that it functioned as a knowingly controlled criminal pass-through account.