What is AMOCE?

"Anti-Money Laundering Meets Military Intelligence"

Anti-money laundering (AML) strategies have traditionally relied on Placement, Layering, and Integration (PLI) to describe the general stages of money laundering. While effective for macro-level understanding, the PLI model lacks the granularity required for detecting, investigating, and disrupting modern laundering tactics, especially in fintech, decentralized finance, and complex cross-border schemes.

The AMOCE framework "Access, Movement, Obfuscation, Conversion, Exploitation" provides a modern, behavior driven and risk based approach to dissecting illicit financial behavior at a tactical level. By integrating AMOCE with PLI, institutions can apply a layered detection and investigative strategy that connects high-level laundering stages to real-world transactional behavior and typologies.

Why AMOCE Was Created

Criminals don’t operate in silos. They evolve, adapt, and exploit system gaps. Traditional AML rules can’t keep up.

AMOCE was developed by AML specialists and former military threat analysts to give institutions a proactive, intelligence-led approach to compliance.

Modern AML Framework

AMOCE reflects the Non-linear, tech-driven and behavior based nature of today's money laundering schemes.

Access:

Gaining entry to the financial system through account openings, wallets, platforms, or intermediaries.

Illicit actors are focusing more on how they access the system than on classic “placement.” If they control multiple entry points, they can skip the traditional "cash in" phase altogether.

Movement:

Rapid transfer of funds through various entities, accounts, platforms, or currencies.

This reflects the speed and complexity of modern laundering. It's about how fast and far the money moves—often in a way that intentionally defies pattern detection.

Obfuscation:

Intentionally disguising the source, ownership, or control of funds.

This step has replaced “layering” but is far more sophisticated due to digital tools and cross-jurisdictional maneuvering.

Conversion:

Changing the form of funds to increase legitimacy, usability, or value.

Integration is now often disguised as normal investment or purchasing behavior—and criminals may not care if the assets are entirely legitimate as long as they’re usable.

Exploitation:

End-use of illicit proceeds for personal gain or reinvestment into criminal enterprise.

This recognizes that the ultimate goal isn’t legitimacy—it’s utility. Whether for crime or comfort, criminals want to enjoy or weaponize the proceeds.

How AMOCE Helps Your Program

Aligns your detection rules with real criminal behavior

Enhances TM, KYC, onboarding, and FIU workflows

Adds adversary thinking to your risk assessment

Improves SAR quality and intelligence value

Enables faster typology response (pig butchering, mule networks, romance fraud, etc.)

Enhancing Anti-Money Laundering Strategi