Legitimuz presents the three most commonly used techniques for money laundering in Brazil.
Money laundering always follows the same logic: transforming resources of illicit origin into something that appears clean and legitimate. The techniques used for this change over time, but three appear most frequently in cases investigated in the country, according to fraud prevention experts.
Fractioning of values
Also known as smurfing, the technique consists of dividing a large amount of money into several smaller deposits or transactions to stay below the thresholds that trigger automatic reports of suspicious transactions. For example, an amount of R$100 could be split into twenty deposits of R$5 each, made over days or weeks, often through different accounts or people.
Each transaction in isolation appears ordinary. Only the aggregate pattern, when analyzed together, reveals the intention behind the movements.
Third-party accounts
Accounts opened in the names of third parties, so-called "straw men," act as intermediaries between the illicit origin of the funds and the final beneficiary. In many cases, the account holder lends their own CPF (Brazilian taxpayer ID number) in exchange for a small amount, or is unaware that their name is being used in this way.
In a typical money laundering scheme, money passes through three or four different third-party accounts before reaching its intended destination, making it difficult for police and compliance agencies to track. The rise in fraud involving Pix (Brazil's instant payment system) has helped popularize this technique in the country, as accounts opened quickly and used for a short time have become an efficient way to receive fraudulent funds before being abandoned.
Mixing with legitimate businesses
The third technique involves injecting illicit money into the revenue of a real business, mixing legitimate income with funds of criminal origin to the point where it is no longer possible to separate one from the other. Businesses that operate primarily with cash, such as restaurants, laundromats, and parking lots, frequently appear in investigations precisely because of the difficulty in auditing the actual volume of sales.
In the digital environment, a variation of the same logic appears on betting and e-commerce platforms, where the business declares a transaction volume consistent with a legitimate operation, but part of that volume originates from illicit funds.
Why the techniques continue to work
According to Thomas Hannickel, Compliance Director and DPO at Legitimuz , the three techniques exploit the same limitation: the difficulty of connecting isolated points that, on their own, seem normal. A deposit of R$ 5 doesn't raise suspicion, an account opened with an apparently valid document doesn't either, and a business that makes good money doesn't attract attention either. The problem only appears when someone manages to observe the complete pattern, cross-referencing different data sources simultaneously.
Prevention systems based solely on fixed rules, such as blocking any transaction above a specific value, tend to have limited effect, since fraudsters adjust their behavior to always stay one step below the known limit.
What the law provides
In Brazil, Law 9.613/1998 criminalizes money laundering and establishes prevention obligations for various sectors, including financial institutions and betting operators. The Council for the Control of Financial Activities (Coaf) receives reports of suspicious transactions from these entities, analyzes patterns that may indicate money laundering, and shares this information with investigative bodies.
