Money Laundering Reporting Officer (MLRO)

According to ACAMS International Glossary of Key Money Laundering Terms and Acronyms, the term 'layering' describes the second phase of the clas­sic three-step money laundering process, which takes place between placement and integration. Layering is the process of sepa­rating illegal proceeds from their source by creat­ing complex layers of financial transactions designed to disguise the audit trail and provide anonymity.

Here is an example of the three steps of the process: criminals deposit drug profits into bank accounts held at a large number of banks, which is placement. Then, they wire these funds to other institutions and convert them into bank checks. They then deposit the bank checks with an insurance company as payments on an insurance policy. Later on, they cancel the policy, having the insurance company wire the money to a law firm's trust account. This is layering. Finally, the drug dealer buys a strip mall using the funds from the attorney’s trust account, which is integration.