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Payments & Banking Technical Explainer

What is a pass-through account?

A pass-through account receives value and moves most of it onward, often retaining little. That observed function can be criminal or legitimate; purpose, control and knowledge require separate evidence.

Incoming and outgoing values rarely match perfectly

Funds may be split, combined, mixed with an existing balance, reduced by fees or withdrawn as cash. Repeated rapid transfers, unrelated senders, low retention and recurring destinations can indicate a movement role, but marketplaces, agents, payroll and family arrangements can look similar.

Establish the account's real operating purpose

Map sources, destinations, amounts, times, references and balances. Compare the pattern with normal activity, stated business or personal purpose, authorised users and recurring counterparties.

Access, endpoint and communications evidence may show who directed transactions, shared credentials, rented the account or retained commission. Describe the pass-through pattern first, then identify what supports knowing movement of criminal funds.

The point to remember

A pass-through pattern describes how value moved; establish purpose, controller and knowledge before treating it as criminal facilitation.

Reference: PAY-139Payments & Banking