When Shadows Move Billions: Rethinking AML in the Age of Grey Networks

March 26, 2025

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Transnational criminal networks—referred to in Thailand as “Gang Jeen Tao” (directly translated as Chinese grey networks)—have quietly infiltrated local economic systems. Rather than relying on overt criminal operations, these sophisticated groups hide behind legitimate-looking businesses to launder illicit funds and carry out illegal activities.

“Gang Jeen Tao” are believed to involve actors operating across East Asia, including long-established syndicates like the Triads. Once associated with traditional crimes such as trafficking and fraud, these groups have evolved into global enterprises that leverage modern financial systems to obscure the flow of illicit wealth. Today, authorities identify them not by nationality, but by their operational patterns, digital sophistication, and international footprint.

Uncovering the Mystery Behind “Gang Jeen Tao”

Thailand has emerged as one of its targets. These grey networks have penetrated the Thai economy, setting up businesses as fronts. These groups exploit mule accounts, bank accounts opened with fake identities, stolen personal data, or via coerced individuals (often victims of human trafficking), making detection difficult without modern AML tools.

Thai authorities recently uncovered more and more of Grey networks, a staggering 55 billion baht circulating secretly within just a single case involving these criminal groups using cryptocurrency to cross-border transfer criminal funds.

This eye-opening discovery underscores just how grey networks have managed to infiltrate Thailand, prompting authorities to significantly strengthen surveillance measures on suspicious financial transactions. Regulations around money laundering have become stricter than ever, reflecting the seriousness of the threat posed by these shadowy organizations. 

Key Takeaways:
  • Grey networks (Gang Jeen Tao) exploit mule accounts, deepfakes, and crypto to launder billions across Southeast Asia.
  • Mule accounts are often opened using fake IDs or through human trafficking, making them hard to detect without AI-based tools.
  • A real-time, multi-source analytics transaction monitoring system is essential.
  • Authorities are adapting, with tech-driven strategies including AI/ML for detection, stronger KYC processes, and global data-sharing.
  • Collaboration between banks, regulators, and law enforcement is crucial to close loopholes and dismantle these evolving criminal webs.

How “Gang Jeen Tao” Exploits Mule Accounts for Money Laundering

Grey networks no longer need to walk into a bank and withdraw stacks of cash physically. Instead, they rely heavily on mule accounts as their primary tool for money laundering. Criminals route funds through these mule accounts in multiple, complex transactions, deliberately obscuring the source and destination of the money. This method creates enormous difficulties for banks attempting to detect and trace illicit financial flows.

Law enforcement agencies now rely on advanced AML technology and dynamic investigative tools to uncover financial trails obscured by grey networks. Mapping the connection of these criminal networks more effectively. Without such a tool, tracing the fund flow on a massive dataset becomes almost impossible, and takes a lot of manpower. and still fall short on taking action in time. 

This investigation technology, 221b Network Analytics, instantly identifies suspicious transaction patterns linked to mule accounts by leveraging AI/ML to rapidly differentiate normal financial behaviors from abnormal ones, greatly enhancing their detection capabilities. 

The strength of this software goes beyond the traditional investigative approach. It excels at tracking all kinds of entities, which can be anything from a traditional bank account, a Personal ID, a Social ID, Crypto wallet, and many more. 

The platform continuously scans all entities—IDs, accounts, crypto wallets—for suspicious behavior, assigning dynamic risk scores to flag potential threats. The system makes identifying high-risk transactions logical and straightforward, enabling quicker, more accurate alerts and streamlined investigations.

Challenges of Tracking the Grey Network's Trails

Even with tighter controls, grey networks remain difficult to detect due to several critical factors:

  • Criminal networks continuously develop with new tactics, using advanced technology
  • Multiple-layer transactions with multiple fake identities and mule accounts
  • Scattered data across multiple platforms
  • Limitations of traditional monitoring systems, not real-time.

How Governments and Regulators are Fighting Back

Money laundering by these grey networks has grown into a severe problem globally, particularly in Southeast Asia, a thriving hub for trade and tourism with vast international money flows. Criminals exploit vulnerabilities in these busy regions, prompting governments and the public sector to respond with stronger preventive measures.

For Banks and FIs, key measures being implemented include:

  1. Stricter and more dynamic Know Your Customer (KYC) process:
    Bank customer identities must be verified using official government-issued IDs, thoroughly investigate the origin of funds to reduce mule accounts, and immediately report any suspicious transactions to authorities, as well as develop new technology to protect against deepfakes

  2. Real-time Transaction Monitoring Systems (TMS):
    Identify unusual money trails as soon as transactions occur. Provide instant alerts to compliance teams when detecting high-risk activities. Quickly identify suspicious financial patterns, such as multi-layered money transfers or mule account usage.

  1. Cryptocurrency Transaction Controls:
    Enforcing KYC standards on crypto exchanges, equivalent to traditional banks. Mandatory reporting of high-value crypto transactions to authorities. Closely monitoring privacy-focused cryptocurrencies (e.g., Monero and Zcash), which offer increased anonymity and are favored by criminals.

  1. Strengthening International Cooperation:
    The Financial Action Task Force (FATF) sets global AML standards. Enhanced international financial information sharing to quickly trace illicit money flows. Cross-border banking cooperation programs that improve efficiency in detecting and investigating international financial crimes.

For Law Enforcement, key measures being implemented include:

  1. Real-time, all-in-one platform that combines and tracks all datasets. from STRs, traditional financial datasets, Personal ID information, Criminal records, to a Blockchain dataset. 
  2. Leveraging AI/ML on investigation skills and data detection.
  3. Mobile Surveillance technology that catches mobile signals. 
  4. Working closely with the public sector to enhance investigations of scammers. ie, Intercom, Internet provider.
  5. Create a robust media to educate the innocent, how to detect scammers and protect their online data.

Conclusion:

As criminal networks grow more sophisticated, the fight against financial crime demands equally advanced tools, sharper vigilance, and deeper collaboration. The case of “Gang Jeen Tao” reminds us that no nation is immune to transnational threats, and no institution can tackle them alone. From AI-powered investigations to real-time transaction monitoring, the future of anti-money laundering is rooted in technology, transparency, and teamwork. The question now is—are we evolving fast enough to outpace them?

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