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.
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.
Please get in touch if you would like to discuss Moody's Shell Company Indicator - we would love to hear from you.