Cuckoo smurfing

Spec sheet // Glossary // CUCKOO SMURFING
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Glossary · AML

Cuckoo smurfing

Also called cuckoo money laundering, hijacked remittance

Definition

Cuckoo smurfing is a money laundering method in which criminals pay cash into the bank account of an innocent person who is expecting an international transfer. The legitimate money sent from abroad is diverted to the criminals overseas. The account holder receives the right amount and usually has no idea the funds are criminal.

SENDER PAYS REMITTERREMITTER DIVERTS FUNDSCRIMINAL CASH DEPOSITERECIPIENT CREDITED
Fig. 1 · Cuckoo smurfing
Proceeds of Crime Act 2002, sections 327 to 329 · FATF Recommendation 20
Key rulesProceeds of Crime Act 2002, sections 327 to 329 · FATF Recommendation 20
Applies toAny person, including bank staff and the depositors
RegionsGlobal · UK
01

How it works

A customer abroad asks a remitter or informal money transfer business to send money to a relative's account in another country. A corrupt operator keeps that money and hands it to a criminal network in the sending country. In the receiving country, the network's couriers pay matching amounts of criminal cash into the relative's account, often in small deposits at several branches. Like a cuckoo laying eggs in another bird's nest, the criminals use an account that is not theirs.

The result is two cleaned flows. Criminal cash enters the banking system through an account with a genuine reason to receive funds, and the criminals abroad receive legitimate money. Warning signs include cash deposits from many depositors and branches into one personal account, deposits that do not match the customer's location, and a customer who expected a wire transfer. Banks investigate these patterns and report them as suspicious activity.

Step 1Spot cash inFlag third-party cash deposits into personal accounts from many branches.
Step 2Compare profileCheck the deposits against the customer's expected international receipts.
Step 3Contact customerAsk how the customer expected the funds to arrive and from whom.
Step 4Trace remitterIdentify the money transfer business used by the sender abroad.
Step 5ReportFile a suspicious activity report without tipping off the depositors.
02

The rules

UK · 24 February 2003Proceeds of Crime Act 2002, sections 327 to 329Proceeds of Crime Act 2002, Part 7, sections 327 (concealing etc), 328 (arrangements) and 329 (acquisition, use and possession)

Make it an offence to conceal, convert, transfer or deal with criminal property, which covers the criminal cash paid into the victim's account.

Any person, including bank staff and the depositors
Global · February 2012FATF Recommendation 20FATF Recommendation 20: Reporting of suspicious transactions

Requires financial institutions that suspect funds are the proceeds of crime to report promptly to the financial intelligence unit.

Financial institutions, through national law
03

Common questions

Is the account holder guilty in cuckoo smurfing?

The account holder is usually an unknowing victim who expected a legitimate transfer. Their account may still be frozen while the bank and the authorities investigate where the cash came from.

How is cuckoo smurfing different from structuring?

Structuring splits cash into small amounts to stay below thresholds. Cuckoo smurfing often uses structured deposits, but its key feature is using an innocent customer's expected international transfer to move value across borders.

Who is most at risk?

Customers who regularly receive money from family or business contacts abroad, such as students, migrant families and people buying property, especially when the sender uses an informal or unregulated money transfer business.