Sanctions Evasion Reference

Professional enabler

A lawyer, accountant, formation agent, broker or similar professional whose services are essential to concealing ownership or moving restricted value.

reviewed

2026-08-20

FATF’s professional money laundering study distinguishes professionals who are exploited by clients from those whose business model is providing concealment as a service. The second group is small, is used repeatedly by unconnected clients, and leaves a distinctive signature: identical structures, identical documents and identical banking arrangements across clients who have nothing to do with each other.

That repetition is what makes them findable. A single structure is opaque; twenty identical ones from the same adviser are a pattern.

Where this term is used

  • What are nominee directors and nominee shareholders? — A nominee is formally recorded as a company's director or shareholder but acts on an undisclosed party's instructions. The register names the nominee; the decisions belong to someone else.
  • What is a professional enabler? — A lawyer, accountant, formation agent or broker whose services are what makes a concealment structure work, and whose repeated involvement across unconnected clients is itself the evidence.
  • What is shell company layering? — Layering is the use of successive companies in different jurisdictions between an asset and its owner, so that no single register, filing or payment record shows the connection between them.

Related terms

  • Corporate services provider — A firm that incorporates and administers companies for clients, supplying registered offices, directors, shareholders and company secretarial services.
  • Nominee director — A person who is formally appointed to a company board but who acts on the instructions of an undisclosed party rather than exercising independent judgement.
  • Facilitation — Approving, financing, guaranteeing, brokering or otherwise assisting a transaction by a foreign person that the assisting party could not lawfully perform itself.
  • Wilful blindness — Deliberately avoiding knowledge of a fact that would create liability, treated in enforcement practice as equivalent to knowing it.

Sources

  1. Professional Money Laundering. Financial Action Task Force, 2018.
  2. Concealment of Beneficial Ownership. Financial Action Task Force and Egmont Group, 2018.

All glossary terms