For AML teams, counterfeiting presents a direct financial crime risk. The manufacture and sale of fake goods generate vast amounts of illicit funds that need to be laundered before they can be reinvested in further criminal activity. Compliance teams in financial institutions, payment processors, and regulated businesses need to be alert to these risks, as failing to detect them can lead to regulatory breaches, financial penalties, and reputational damage.
One of the biggest red flags is unusual risk patterns, particularly for businesses dealing in high-risk industries. Shell companies set up as ‘wholesalers’ or ‘import/export’ firms can be used as fronts for counterfeit operations. Transactions that seem inconsistent with a company’s profile – such as unusually high payments to suppliers in known counterfeit hubs or frequent high-volume cash deposits – should prompt further scrutiny.
Another key area of focus is trade-based money laundering (TBML). Counterfeit goods are often moved through complex global supply chains, using fake invoices, undervaluation, and misclassification to disguise illicit funds. Compliance teams should be examining trade finance transactions closely, looking for discrepancies between declared goods and actual shipments, as well as identifying counterparties linked to known high-risk jurisdictions.
AML teams must also be wary of how counterfeit goods are sold. The rise of online marketplaces and social media has made it easier for criminals to distribute fakes while remaining anonymous. Payment fraud, fake reviews, and anonymous seller profiles all play a role in these schemes. Unusual payment flows – such as multiple small transactions processed through digital wallets or peer-to-peer platforms – may indicate efforts to disguise illegal earnings.