Fictional training scenario — not real intelligence

Practical exercise

The Vantrell Ledger

IntermediateFinancial intelligence~35 min6 reports

Tasking

Requested by: Priya Nandakumar, Head of Financial Crime Investigations, Tallowmere Mutual Bank
Key question: Is Vantrell Freight likely being used to move illicit funds through trade — and what do we still need to know before the bank acts?
Deadline: Assessment to the Financial Crime Committee, Thursday 0900.

Vantrell Freight Pty Ltd banks with Tallowmere Mutual, a mid-sized regional bank. Transaction monitoring flagged the account last week and the relationship manager has since visited the company. The bank must decide whether to lodge a suspicious matter report with the regulator and whether to keep the customer. You work in the bank's financial crime intelligence team. You do not decide — you assess, so the people who decide can do it properly. All amounts are in dollars.

Brief pack · 6 reports

Transaction monitoring alert summary

3 Sep

Bank system data: Tallowmere Mutual's transaction monitoring system, extracted and checked by the alerts team. Covers 1 May – 31 Aug.

Inbound: 37 transfers totalling $2,864,000 from 11 companies. 29 of the 37 are round amounts ($50,000, $75,000, $95,000). Four of the 11 paying companies list the same registered office as Vantrell: Suite 4, 18 Merchant Lane, an accountant's virtual office. Outbound: 31 international transfers totalling $2,790,000, usually within 48 hours of an inbound payment — 64% to Velantia Pumpworks Ltd (Republic of Velantia), 36% to an account in the Marrick Islands held by Orrin Bay Trading Ltd. The balance has never exceeded $40,000. No payroll, rent or utility payments go through this account.

Company registry extract: Vantrell Freight Pty Ltd

4 Sep

Official record: Government corporate registry search, run by you this morning.

Registered 14 months ago. Sole director: Callum BRIGHTWATER. Registered office: Suite 4, 18 Merchant Lane (shared with 31 other companies). Sole shareholder: Orrin Bay Holdings Ltd, incorporated in the Marrick Islands. The Marrick Islands do not publish shareholder or beneficial-ownership registers. Brightwater is also director of two other companies registered in the last 18 months at the same address. Neither has lodged financial reports.

Partner agency trade data: Vantrell imports

6 Sep

Partner agency data: Border agency import declarations, provided under a formal information-sharing arrangement. The weight comparison was prepared by a border agency trade analyst.

Three consignments declared as "industrial centrifugal pumps" from Velantia Pumpworks Ltd; consignee Vantrell Freight, Port Calder. Total declared value: $2,130,000. Total gross weight on the bills of lading: 18,400 kg. Analyst comment: "Pumps of the declared models at this value would typically ship at 55,000–70,000 kg. Either the declared value is inflated roughly threefold or the description is wrong. No physical inspection was carried out on any of the three consignments."

Trade press profile

Published 11 Mar

Open source: Article in Cargo Ledger, an industry newsletter, published six months ago. Generally accurate, but its company profiles are based on interviews with the companies themselves.

"Vantrell Freight is one of Port Calder's fastest-growing importers, says director Callum Brightwater. 'Our Velantian partners give us an edge on price,' he said. The company now employs 40 staff and runs a 3,000-square-metre warehouse on the Port Calder industrial estate."

Relationship manager's site visit note

5 Sep, 1415

Human source (first-hand): Tallowmere Mutual relationship manager, eleven years with the bank. Her previous site-visit reports have been accurate.

Visited the address on file: Unit 7, Lot 22, Port Calder industrial estate. It is a small shared unit (roughly 300 m²) with signage for Vantrell and three other businesses. Two people present; one described them as "the operations team". No pumps, pallets or forklifts visible. Mr Brightwater was friendly and said the pumps "go straight from the wharf to customers' sites, so there's nothing to see here". He offered to send invoices.

Letter from Vantrell's accountant

8 Sep

Subject-provided: Letter from Vantrell's external accountant, sent in response to the bank's request for information. The accountant's firm runs the virtual office at Suite 4, 18 Merchant Lane.

"The round-sum payments are customer deposits for pump orders. Vantrell forwards them to the manufacturer, Velantia Pumpworks, and to its regional distributor, Orrin Bay Trading, which handles shipping. Pumps are delivered directly from the wharf to customers. Three sample invoices are attached." The attached invoices show unit prices matching the declared customs values. They are on Vantrell letterhead and are not signed by any customer.

Brief pack (6 reports)