Key Highlights: Wash Trading

What Is Wash Trading in an AML/CFT Context

Wash trading is a fake trading activity in which the trader simultaneously buys and sells the same financial instruments (or assets) to create artificial activity. This market manipulation technique makes the asset look active and creates an illusion of high demand and inflates trading volume, without any change in beneficial ownership.

 

Wash trading distorts market signals by influencing investors’ decisions with constant buying and selling at higher prices to generate illicit gains. This practice has risen in cryptocurrency markets with relatively less regulatory oversight.

 

Wash trading is positioned as a predicate offence within the financial crime framework, helping criminals generate illegal proceeds for money laundering, fraud and tax evasion.

How Wash Trading Intersects with Money Laundering

Wash trading is a common money laundering method that criminals use to circulate funds by executing a fake trade to make dirty money appear to be clean profits.

 

Criminals use linked accounts or platforms to repeatedly buy and sell the same asset and fake trading activity, to deceive market participants and conceal an illicit source of money.

 

Further, this trade-based manipulation technique helps criminals integrate illicit proceeds into financial systems and pull out as clean money, presenting them as proceeds of trade activity.

Red Flags and Suspicious Indicators of Wash Trading

Common red flags and signals indicating wash trading activity are as follows:
  • Buying and selling of assets between the same or related accounts is a practice called self-trading.
  • Rapid buy and sell of the same asset in a short duration with minimal or no net change in beneficial ownership or position.
  • Repeated or sudden hike in trading volumes, driven not by genuine investment intent, profit motive or market speculation.
  • Trades with no economic purpose, showing patterns inconsistent with customer profile or normal trading behaviour.

Regulatory Expectations for Detecting Wash Trading

Regulators expect regulated entities to use automated systems to monitor trading activity and identify trade-based manipulation patterns. This includes detecting wash trading with updated systems to identify evolving fake trading activity. Further, regulators require entities to investigate suspicious wash trading activities and report them to the associated authority. With this, entities should also coordinate with regulatory authorities, providing transparency and information sharing to avoid regulatory penalties. Regulators mandate entities to document CDD records and decision rationales to provide evidence of compliance to authorities. Also, entities must maintain audit trails to ensure accountability and traceability and improve the quality of investigations.

Detecting Wash Trading Risk with Citadel365

Citadel365 provides comprehensive support to identify wash trading-related risks. The customer onboarding software helps verify customers before establishing relationships, and its risk assessment software develops a customer risk profile based on customer trading behaviour.

 

Citadel365 transaction monitoring software helps detect hidden relationships and unusual patterns such as circular trading patterns, layering, and self-trading. Moreover, the case management software automates investigation workflows, and its effective audit trails support regulatory review.

Strengthening Controls Against Market Manipulation Risks

Regulated entities must define and implement effective AML controls to prevent market manipulation risks, which include:

 

Customer Due Diligence: Apply a risk-based approach to identify and verify customers, including beneficial owners, and implement enhanced due diligence for high-risk trading customers.  

 

Risk Assessment: Integrate customers’ real-time trade data or trading behaviour to assess customer risk and apply risk scores.

 

Ongoing Monitoring: Entities should perform continuous transaction monitoring to detect unusual trading patterns and anomalies.

 

Governance and Reporting: Use a centralised platform for documentation and audit trails to support regulatory inquiries and avoid penalties.

Wash Trading FAQs for AML Professionals