中国证券业协会下发的《证券公司开展第三方存管单客户多银行服务指南》(以下简称《指南》)中禁止在辅助资金账户之间划转资金。我们假设,洗钱分子极有可能通过A银行将资金划入主资金账户,通过主资金账户将资金转入辅助资金账户,辅助资金账户的资金再转入其对应的开户银行;或者通过B、C、D、E中的任意银行将资金转入其对应的辅助资金账户,再转入主资金账户,通过主资金账户直接划入其对应的A银行,或划入其他辅助账户后再转入 The Guidelines for Carrying Out Multi-bank Third-party Depository and Escrow Services by Securities Companies (the “Guidelines”) issued by China Securities Association prohibit the transfer of funds between auxiliary funds accounts. We assume that money launderers are most likely to transfer funds to the main funds account through bank A, transfer funds to the auxiliary funds account through the main funds account, funds from the auxiliary funds account to their counterpart bank, or through B, C , Any bank in D and E transfers funds to its corresponding ancillary funds account and then transfers it to the main capital account and directly into its corresponding bank A through the main capital account or into other ancillary accounts