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Seven indicators of shell company risk



Shell companies can be used by criminals to conceal offenses such as fraud, tax crime, money laundering, and sanctions evasion, all of which pose a threat to the global economy. Against this background, there are significant moves from governments and the private sector to create more corporate transparency.

One of Moody’s approaches to supporting customers in this area of financial crime detection, compliance, and risk management is through our Shell Company Indicator.

By raising flags that relate to suspicious shell company behaviors, customers can integrate this information into their compliance, risk analysis, and due diligence processes. It can be used as part of a holistic approach to understanding who you are doing business with, so decisions can be made with confidence.

Moody’s has identified seven indicators of shell company risk. The risks surfaced through one or more of these indicators suggest the potential presence of a shell company, which may warrant more targeted investigations.


(1)        Numbers refer to the total number of companies within the Moody’s dataset that have or display this outlier or anomalous characteristic.


  1. Outlier directorships
    Individuals holding an unrealistic number of directorships can flag potential risks. Moody’s data shows that one person was observed to have 5,751 roles in 2,883 companies. Such prolific involvement raises flags that can prompt further investigation into these interconnected companies. Within the Moody’s dataset, there are 11.5 million outlier directorships flags.

  2. Mass registration
    Mass registration is a flag for shell company risk involving corporate formation patterns where companies share names, addresses, or directors. Moody’s Shell Company Indicator is able to identify a strip mall in South Africa with 61,000 registered businesses since 1998 and an address given as the “Pyramids” in Egypt that hosts more than 22,000 companies. The scale of registrations such as these could suggest systematic efforts to obfuscate ownership, which may demand further investigation. There are 4.2 million instances of mass registration within Moody’s dataset.

  3. Jurisdictional risk
    Jurisdictional information can provide an indication of shell company risk. For instance, if the identified nationality or residency of an individual director or beneficial owner is different from the company's country of registration, and at least one of these jurisdictions is defined as high risk, it may warrant further review. Shell Company Indicator flags 1.2 million individual-company combinations with jurisdictional risk.

  4. Financial anomalies
    The Shell Company Indicator raises flags on 3.4 million companies with financial anomalies. These extreme financial anomalies are another outlier that can indicate suspicious shell company behavior, i.e. when the revenue of a firm appears to be way out of odds with the number of employees – this may present as millions of dollars in revenue, but only a handful of employees. These financial anomalies are useful to law enforcement and government agencies trying to investigate and disrupt criminal networks.

  5. Dormancy
    Dormancy flags show companies that have laid dormant for extended periods - Moody’s has identified more than 655,000. Dormancy can be an indication that the company is being strategically "aged" to avoid detection before being used for criminal purposes, such as money laundering. There are cases of businesses that have been dormant for several years before seeing a sudden spike revenue, which could be viewed as a risk worth investigating.

  6. Circular ownership
    Circular ownership flags identify companies entangled in circular relationships, which can be a sign of fraudulent transactions and money laundering, as circular ownership can create complexity to deliberately obscure true beneficial ownership. Indicators of circular ownership can include instances such as a company without a website or digital presence, but with various concurrent directorships. Moody’s data has identified more than 60,000 flags for companies engaging in circular ownership.

  7. Outlier ages
    Information that shows outliers to an expected norm, even one with a very wide range, can be an indicator of shell company risk. For example, the age of a company’s beneficial owner can be improbably elderly or young. Moody’s data shows that some firms have beneficial owners who are older than 122 (the oldest living human is 116) and as young as 0. These extreme ages indicate potential risk and can help organizations target further investigations. Moody’s Shell Company Indicator shows more than 38,000 instances where a beneficial owner is flagged by this outlier ages typology.



The evolution of risk and solving a global challenge

The number of companies flagged for shell company behaviors actually dropped significantly after 2016, following the Panama Papers exposé. However, individual flags show shifting patterns, which can often be influenced by global events. Since 2022, for instance, jurisdictional risk flags have become more common, largely affected by increasing sanctions following Russia's invasion of Ukraine. Understanding and surfacing these trends of how individuals hide themselves and their illicit activities in shell companies is crucial for adapting risk analysis, as well as detecting, investigating, deterring, and reporting suspicious behavior.

Advancements made through Moody’s analysis and detection tool can help tackle the persistent use of shell companies. Simultaneously, there are various pieces of national legislation such as the US Corporate Transparency Act, the UK’s Companies House Register of Overseas Entities, and ATAD III in the EU, designed to create corporate transparency and prevent the misuse of shell companies to facilitate financial crime.

However, the scale of the task is made clear by the estimated $1.6 trillion laundered each year globally, showing the need for sustained efforts to stay ahead of evolving risks.




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