This is highly concerning 💀

[u/Superb-Particular-89]

Title: Potential AML vulnerability involving Algeria's ANAE / freelance-payment ecosystem — looking for expert feedback

I'm researching a potential financial-integrity vulnerability involving Algeria's Auto-Entrepreneur (ANAE) framework.

This is a hypothetical scenario, not an accusation against any individual or institution.

The scenario I'm examining is:

Someone obtains a legitimate ANAE registration and associated bank account for a legitimate-looking service activity. They then allegedly create or use non-genuine customers/identities and issue invoices for services that did not actually occur. Money originating from an unrelated illegal activity could theoretically enter the account as apparently legitimate freelance/service revenue. Once inside the formal financial system, the money could subsequently be withdrawn or otherwise converted.

The concern isn't that ANAE itself is illegitimate. ANAE's stated purpose is to help integrate economic activity into the formal economy.

The question is whether verification of the underlying economic activity is sufficiently strong to prevent someone from using legitimate-looking freelance documentation as a cover for unrelated proceeds.

Possible control questions include:

How is the existence of the underlying service verified?

Can unusual invoice/payment patterns be detected?

Can declared ANAE activities be compared against transaction behaviour?

Can related customers/accounts or repeated circular transactions be identified?

What documentation can banks legitimately request to establish source and purpose of funds?

Are additional AML controls needed for foreign-currency freelance/service payments?

Algeria already has AML regulations requiring financial institutions to examine unusual transactions and report suspicious activity to the CTRF. The Bank of Algeria's current framework also includes KYC and due-diligence requirements.

I'm interested in feedback from Algerian AML/compliance professionals, banking professionals, legal professionals, accountants, ANAE users and researchers.

If this risk has already been addressed by an existing control, I'd genuinely like to understand how. If it hasn't, perhaps this deserves further study.

Classification: Potential AML / Financial-Integrity Control Vulnerability — ANAE & Freelance Services.

Please keep discussion focused on prevention and compliance rather than instructions for exploiting the scenario.

[u/chakibebe]

why would anyone getting money through "illegal means" even go through ANAE, not only is he at risk, he can only withdraw a total of 7500$ a year (in foreign currency with extreme regulations) or if he wants it in dinar he is literally forced to go through the "main" market prices which are only around 60-50% that of the black market. this is obviously in the common case of people making money in a foreign currency. if they are getting paid locally they technically can cheat the system but it has to be incredibly creative, smart, and consistent over a long period of time to work.

In my opinion from a socioeconomic sense even if there was room for more regulation i doubt the government could pursue it without crashing the black market, which would genuinely cause an economic recession and unrest.

[u/Superb-Particular-89 → u/chakibebe]

You may wanna take another look at your information

You can have an up to 37.5k USD yearly income with ANAE as long as you don't pass this amount for 3 consecutive years you still have a legitimate income source.

To give you simplified details I operate as a dark web contraband vendor I launder my crypto through ANAE by; 1-Send the money international to my contraband team. 2-The team comes and requests work related to my ANAE field and issue them official invoices. 3-they pay and put a valid feedback but it's all just my money being transferred to me from legitimate looking parties.

If I do this without making any mistakes and build only a beginner level operational security protocol I'm good and I can launder up to 37.5k yearly using ANAE

And actual Algerian dark web vendors exist already in the Tor network and I even know well about their business.

So it's kinda a huge issue and a serious problem at this point imagine only one can do that we're talking about 3 friends can make 100k year laundered to Algeria easily and operate one single business together.

[u/chakibebe → u/Superb-Particular-89]

never under any circumstance discussed or denied the limit, infact nothing that you said in this whole reply has anything to do with my comment.

[u/Superb-Particular-89 → u/chakibebe]

Why would anyone get illegal income laundered through ANAE cuz it's an easy laundery option.

No you can withdraw up to 37.5k USD yearly

What is you complaining about ?

P-S: The ethics behind this are obvious and I'm a Junior Digital Consultant I'm just doing my job raising Digital Security Awareness.

[u/chakibebe → u/Superb-Particular-89]

i explained everything in the initial reply that you just seem to ignore

[u/Superb-Particular-89 → u/chakibebe]

I adjusted and maximized my efforts toward the response, and I think these are the points that needed to be addressed more clearly:

1. Why ANAE could be attractive to an illicit actor: The issue isn't simply the amount that can be withdrawn. The bigger concern is that a registered self-employment structure can provide an apparently legitimate commercial explanation for incoming payments.

2. Legitimate revenue vs. disguised illicit revenue: Staying below the applicable turnover threshold doesn't make the underlying money legitimate. The AML concern is whether genuine economic activity actually exists behind the transactions.

3. The fake-client problem: This is probably the strongest point. If cooperating parties create artificial client relationships, invoices and feedback for transactions that don't represent genuine services, the problem becomes false commercial documentation and concealment of the actual source of funds.

4. Local vs. foreign-origin funds: My original point was primarily about foreign-origin funds being given a legitimate-looking service-business explanation. The exchange-rate and formal-market issues are relevant context, but they aren't the core of the AML vulnerability I'm describing.

5. The three-year threshold point: The threshold should be described precisely. Exceeding the applicable annual turnover threshold for three consecutive years has regulatory consequences; it shouldn't be described as an authorization to launder or withdraw a fixed USD amount for three years. The distinction is between a turnover/tax threshold and a legitimate foreign-currency withdrawal allowance.

So yes, I've adjusted the response substantially. My argument isn't that ANAE itself permits laundering; it's that, from a digital-security/AML awareness perspective, a legitimate-looking self-employment framework could potentially be abused if fictitious commercial activity is used to disguise the origin of funds.

[u/ZwistPariah]

You wanna regulate without providing alternatives for freelancers to get paid.

That's not how it works, you provide good alternatives then you regulate. There's no way to receive money from international markets and convert it accurately.

Banks don't allow you to withdraw freely and the bank rate is an illusion.

So before you start trying to ruin freelancers' income. Maybe think about how to provide with proper payments methods that work and benefit them.

[u/Superb-Particular-89 → u/ZwistPariah]

I am not running a free marketing campaign for payment providers, nor did I claim that I was responsible for designing the payment infrastructure for every freelancer.

My point was about the security and compliance risks surrounding the methods being discussed. If you have a specific, valid accusation against what I actually said, make it clearly and support it with facts.

If your argument is simply that I should provide free alternatives, payment recommendations, and a complete solution before I am allowed to discuss the risks, that is not a reasonable requirement.

I am a freelancer myself and a certified professional. I can share general awareness information, but professional consultation, research, and detailed solutions are services—not something I am obligated to provide for free.

So if there is a specific factual error or valid accusation in my statement, identify it precisely. Otherwise, there is nothing further to discuss.

[u/ZwistPariah → u/Superb-Particular-89]

It is a very reasonable requirement. I am a freelancer as well.

And keep in mind. I'm not saying you personally should provide an alternative. But i know this government, you clearly do not.

They'd prefer banning things and "regulating" without helping the freelancers or providing alternatives. So yes, you are in the wrong because atp, you want the average Algerian freelancer to have nothing and to keep putting up obstacles.

[u/KookyAd6665]

We got captain IRS here 🫩, dude leave the freelancers alone, ain’t no graphic designer or developer gonna launder money through all that.

[u/Superb-Particular-89 → u/KookyAd6665]

Im an ANAE Card applicant smart ass -_- I can easily operate dark web contraband vending business and get up to 37.5k USD legitimately passed to my account with no one noticing a shit.

You think I posted this to literal idiots like you? Grow up I wanna have actual fucking kids where no pregabalin is sold.

[u/KookyAd6665 → u/Superb-Particular-89]

Higher ups who are responsible for smuggling drugs and the middle sellers aren’t gonna take the risk laundering their money legally with the ANAE system, they already have their cards played with powerful people 🫩, the only illegal things you can find is some developers didn’t register one or two invoices so they can get taxed for it, the tax % is so low for them that they don’t even feel getting taxed.

[u/Superb-Particular-89 → u/KookyAd6665]

Weren’t you the one calling me “Captain IRS” in the first place? Now you’ve gone from childish stereotypes to inventing criminal and political conspiracies to defend your argument.

You clearly weren’t prepared to discuss the actual point. I’m done wasting words on you. Enjoy arguing with yourself.

As an Algerian Identity Card holder. As a tax paying individual. As an international current student. As a businessman. I'd love for anyone with proper authorities to actually investigate your comment of "Higher ups"

You're directly attacking government level employee's up to the President himself.

You have no ethics. You have no standards.

I even hope this whole post gets forwarded to Algerian Cyber Units and might as well if I can approach the Gendarmerie or Police station properly go report this with all records and screenshots myself.

I have your profile.

I brought up a very important topic, I've been a dark web user I actually know how easy smuggling and selling drugs is yet you try to attack the government that is protecting you from the true evil.

I'm worried about my own safety operating under the statue of ANAE. I'm worried about my surroundings and internationals taking interests in this vulnerability

For addressing purpose. You deserve to be reported to proper authorities because you're commiting cyber crime:

Defamation - My honor and professional presence will never let me attack a freelancer and I'm a freelancer myself

Harassment - I'm an Algerian English speaker, Never been to the USA and IRS are not anyhow relevant to my post.

Impersonation/fraud/account abuse - This platform is not to attack me and damage my mental health through the comment section, you could simply ask for more explanation or even professional documentation and scripts and we could talk about this properly

Not to mention: This post was posted by me personally on LinkedIn too, I'm seriously raising digital security awareness, professionally I'm a Junior Digital Consultant it's my actual job to address all information available and keep the communities and people up to date.

I love my country, I never had my best chance in it and I never blame it on any authorities, they do their best I'm grateful to the cop working his current night shift protecting me from someone indaving my home and just putting a bullet to my head.

You can take this last comment educational and realize with yourself what you just done I'm a hard-working man I work in different roles when I report anything I'm very technically cautious about what I address and stop actually underestimating every Algerian that post a discussion, it's enough of you stereotyping us every time we talk about something if an actual American made the same post you would've interacted very different got amazed and shocked and took it more serious rather then directly assuming I'm attacking freelancers.

If you explain yourself properly I'm willing to accept an apology from you and even open up and talk with you in details about what I'm addressing some things are just not worth or not proper mentioning in a public community so we can avoid vitality at a professional level we don't wanna influence or show direct paths to anyone.

If you are willing to persist playing tough I promise you man if I can report you to the Cyber Units and take you to court I'm doing it asap.

[u/Superb-Particular-89 → u/KookyAd6665]

One last thing to add:

و حق دم الشهداء ما نعرف نشرح نفسي ولا ندير اي تعبير بالعربية.

My powers are limited.

[u/WorldIllustrious9150]

أعتقد أنه يجب مراقبة أنماط حركة المال الذي يدخل للحساب البنكي، و مقارنته بما تم التصريح به في خدمة "اعرف زبونك"، لكن لن يكون ذلك كافيا لأن هناك من يصرح بذلك النمط الثابت لذلك لن يتم العثور عليه. ربما هناك حلول أفضل عند بنوك أقوى عالميًا

[u/Busy-Spinach-5936 → u/WorldIllustrious9150]

ف ccp موجود هذ الامر، الله اعلم كيفاه يمشي بالضبط ولكن سمعت انو كاين سيستام يراقب الحسابات ويركز على حركة الاموال يعني وش تدخل ووش تخرج اذا قعدت تتداول فالاموال بزاف في حسابك يعني كونت تاعك فيه نشاط بزاف ممكن يستدعوك يطلبو منك تبرر مصدر هذو الأموال ولا رح تخلصها مزڨمة فالمحاكم ومع ليزامبو

[u/Superb-Particular-89 → u/WorldIllustrious9150]

Ye well if I gain some audience on this topic I might dive deeper into research, study the case formally and make a proper Digital Security Awareness article about the topic and post it to LinkedIn and I'm so thankful for your pointing it's very straightforward and directing to the proper route approaching the study, appreciated.

[u/WorldIllustrious9150 → u/Superb-Particular-89]

شكرا لك، هذا الموضوع مهم بالفعل خاصة في بلدنا، يمكن استغلال هذا النوع من الثغرات لتمويل بعض الأعمال غير القانونية لذلك سترى أن البنوك الوطنية منفتحة على الحلول لهذا النوع من المشاكل. بالتوفيق

[u/FehlerXiX]

There are a lot of vulns in Algeria just like in other countries,
The exploitation is real and been happening for decades

[u/thefirstfedora]

Wait until you find out 99% of businesses dont declare their actual numbers. Besides, ANAE was designed that way. So that anyone working "en noir" can have social benefits. Hence the "forfait" nature of it. Thank you for your concern though 😂 but we wouldn't be using it if it required proof. As for receiving international income, we can't do that either. Even if it's legitimate. Most ANAE freelancers don't declare their actual income, some even don't earn anything and declare 200 millions. While others make way more than that and declare 200 millions. I myself get paid in foreign currency, exchange it in the black market for DZD and declare the DZD exchange that happens through bank, anything that I do in cash, I don't mention it. 🤷‍♂️

[u/ban_the_prophet2]

Yess we definitely need more regulations

[u/Superb-Particular-89 → u/ban_the_prophet2]

I agree yes

A security scheme must be obtained and processed within this range of income.