Distinguishing Money Laundering from Embezzlement

by Oct 20, 2023

Distinguishing Money Laundering from Embezzlement

Oct 20, 2023 | Blog, KYC, News & Events

With the world of financial crime constantly shifting and evolving, navigating illicit activities has become increasingly complex. Two prominent crimes within the financial sector are money laundering and embezzling, and while both do pose significant risk to customers and institutions, their overall impact and future applications are quite different. From an Anti-Money Laundering (AML) standpoint it is particularly valuable to understand the distinctions between the two, as well as the importance of compliance with regulatory standards.

Below, we’ll take a closer look at the defining differences between money laundering and embezzlement; read on to learn more.

Embezzlement: A Crime of Trust

Embezzlement is one of the most referenced forms of white collar crime and involves the misappropriation of funds or assets entrusted to an individual within an organization or business. Embezzlement does not inherently involve the integration or use of illicit funds (though it may in rare circumstances), and instead centres on a breach of trust and fiduciary duty. Embezzlement is typically conducted by employees or high-level executives in a position of power within an organization that handles financial assets ad occurs when the individual(s) in question divert company or public funds for personal gain. Diverting funds can take many forms, with common methods including forging checks, diverting payments, or misusing company credit cards.

The most important distinction between embezzling and money laundering is that embezzled funds are typically fully “legitimate” and thus do not need to be “cleaned”, unlike the illicit funds moved around by money launderers.

Embezzlement is typically addressed through internal controls, audits, and legal actions, often levied against a sole actor opposed to a criminal network. Since embezzled funds start as legitimate, detecting and preventing embezzlement requires organizations to implement strong financial oversight, segregation of duties, and regular audits to identify irregularities. Routine monitoring, internal KYC protocols for employees and prospective hires, as well thorough quarterly and annual reporting can help serve as preventative measures.

Money Laundering: Unmasking the Layers

Money laundering is a sophisticated process wherein illegally obtained funds are camouflaged or “cleaned” in order to appear legitimate within the financial system. Cleaning helps criminals to remove suspicion for criminals networks, allowing them to operate undetected with such funds typically being used to enable various illicit activities throughout the global stage.

In order to successfully launder funds, there are three key stages that must be completed; placement, layering, and integration.

Placement: During the initial stage of laundering”dirty money” from criminal activities, such as drug trafficking or corruption, is introduced into the financial system. To avoid early detection, criminals will often distance themselves from the source of funds, typically by depositing them in various across multiple financial institutions.

Layering: Once money has been placed in the accounts mentioned above, launderers begin the process of obscuring any transaction trails and masking their illicit funds. Criminals may conduct multiple micro transactions between accounts (larger transfers are more likely to be flagged), buy and sell assets, or engage in international transfers, and utilize decentralized financial vendors to complication tracking efforts.

Integration: Finally, when funds have been “cleaned” by being moved through various avenues, funds are then reintroduced into the legitimate economy and organically exchanged by unsuspecting individuals and entities. Once funds reach the integration stage, it can be highly difficult to trace their original point of origin, allowing criminal networks to hide behind what now appears to be a long trail of legal, legitimate transactions.

AML Focus on Money Laundering


Global legislators recognize the extreme threat posed by money laundering. While embezzling stands to affect multiple individuals through the loss of funds, the ethical and humanitarian implications of money laundering are much greater. Laundered funds are often used to enable dangerous and highly illicit activities such as funding the global black market, human trafficking, finance the drug trade, weapons dealing, terrorist financing, and more. AML policies and procedures seek to circumvent the opportunity for criminals to achieve their malicious objectives, and focus on vigilance, due diligence, and reporting as well as refining preventive and detection methods.

From an AML perspective, the primary concern is preventing the integration of illicit funds into the legitimate financial system. Financial institutions and businesses implement robust AML policies and procedures to identify and report suspicious transactions, which could indicate money laundering activities. AML efforts focus on vigilance, due diligence, and reporting to authorities, with an emphasis on the detection and prevention of financial crimes that seek to legitimize the proceeds of criminal activities. Compliance with such measures is essential for building a safer market for all, and for avoiding costly fines and legal repercussions for your business.

Your Partners in AML Compliance

At iComply, we are proud to partner with businesses and institutions across North America and Europe to empower streamlined AML compliance and preventive practices. We offer a modular suite of KYC and AML products that makes compliance simple and cost-effective to achieve, and are pleased to be a trusted source of KYC support.

Learn more about the benefits of iComply’s award-winning suite of AML and KYC software by booking a demo today.

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