Report

Read about terrorists’ abuse of these platforms in our Expert Insight: Terrorist Use of Crowdfunding in which we discuss FATF’s findings and delve deeper into key topics to consider including:
- Charities and Non-Profits
- Social Media and Messaging Applications
- The Use of Virtual Assets
- Detection of Terrorist and Extremist Activity
- Information Sharing with Law Enforcement
- Key Red Flags
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When Holiday Cheer Meets Fraud Pressure
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Navigating the Convergence of Sanctions Evasion, Export Control Evasion, and Money Laundering
Explore the convergence of illicit finance domains through real-life examples including Russia’s procurement of drone components, Iran’s evasion networks, and China’s acquisition of restricted chips.

Operation Mouse
Synthetic identities are increasingly used to perpetrate fraud. Delve into real-life examples of synthetic identity fraud in Canada, along with the actions financial institutions can take in response, in this article.

Laundering Luxury
‘Daigou’ buyers purchasing luxury items in the U.S. for sale in China are often funded by Chinese Money Laundering Networks using financial proceeds of cartel activities. Learn how these methods operate, the red flags financial institutions can identify, and the actions to take in response.

Terrorist Drug Trafficking Organizations
This article provides background on designated cartels — their geographic reach, how they raise and move money, the risks they pose to financial institutions, and common red flags that may help financial institutions to identify suspicious activity.

FATF’s Recent Risk Map Update
FATF’s June 2025 update—new grey list additions and unchanged high-risk jurisdictions mean updated risk scores, stronger due diligence, and sharper monitoring for compliance teams. Here are three actions to take now.

Deepfake Deep Dive
Artificial intelligence (AI) can increase the volume, value, and effectiveness of fraud attacks such as CEO fraud. Financial institutions should take action to protect themselves – and their customers.

Blockchain & Ballistics
The Houthis are pioneering a new model of terrorist financing by using digital assets to purchase advanced weapons systems. This article explores the new dimensions of this convergence, and red flags associated with these evolving risks.

Out of the Shadows
Iran’s shadow banking system has laundered billions of dollars for the regime. In this article, we detail how the system works and how financial institutions can identify red flags associated with Iran’s oil smuggling and concealed payment networks.

Cartels & Crypto
Cartels and the professional money launderers that service them have integrated digital assets throughout the narcotics trade, from precursors to sales and laundering proceeds.

Canada’s Strong Borders Act
Canada’s Strong Borders Act represents a sweeping overhaul of the country’s AML/CFT regime. The legislation introduces tougher penalties, expanded oversight, and stricter compliance and enforcement expectations.

A Dangerous Alliance
Today, on United Nations International Day Against Drug Abuse and Illicit Trafficking, we spotlight a dangerous financial alliance accelerating the fentanyl crisis: transnational partnerships between Mexican cartels and Chinese money laundering networks.

From Fraud to Flow
Fraud is often the entry point into a complex web of financial crime from money laundering to terrorism financing. Understanding this gateway role is essential for those defending the integrity of the global financial system.

The Network, Not the Node
Data analytics and advanced technologies are critical tools to take effective action against increasingly complex criminal networks. In this article we consider the best practices a financial institution could apply when implementing data analytics strategies and solutions, and what the future holds.

Sweeping AML Requirements for RIAs and ERAs
FINCEN issued a final rule with new AML requirements for investment advisers. With the January 1, 2026 deadline approaching, RIA and ERA firms must begin building and implementing their compliance programs as soon as possible.

Cartels, Cash, and Capital Flows
Cartels and their money laundering networks represent an increasing threat to our security and citizens, as well as being a priority for enforcement action. This article sets out five actionable steps a financial institution can take to ensure it is effectively identifying and responding to cartel risk.

Syndicates of Terror
Eight Latin American drug cartels were recently designated by the United States as Foreign Terrorist Organizations and Specially Designated Global Terrorists. The U.S. designation enhances compliance risks for financial institutions and other companies transacting in Latin America.

Navigating the Convergence of Sanctions & AML Regimes
In our recent webinar, the director of compliance and enforcement at OFAC and three financial integrity industry leaders discussed the importance of breaking down silos and shared other advice for AML/CFT and sanctions professionals.

Interlocking Action
Transnational crime requires a coordinated response. Examine the characteristics of transnational crime, breakdowns in internal cooperation within financial institutions that resulted in enforcement action, and the actions Chief Compliance Officers must take to ensure an effective and coordinated response within their institution.

The Heat is On
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The New Counter-Illicit Finance Regime
The convergence of AML/CFT and sanctions regimes has led to a paradigm shift. These disciplines may now be viewed as overlapping parts of a broader global counter-illicit finance regime.

Examining Evasion
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Wicked Games
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The Chips Are Down
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2024’s Top 10 Major Developments
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Syria Sanctions Relief
The U.S. Treasury has issued a Syria General License to provide gradual sanctions relief for the Syrian people after the regime of Bashar al-Assad was toppled in December 2024. What does this sanctions relief mean to financial institutions and other firms hoping to transact in the country?

Shell Companies as an Enabler of Export Control Violations
Shell companies are a key enabler of export control violations, which represents an extension of their well-established use in other financial crimes. This article provides red flags financial institutions can use to identify shell companies in the export control context and to take action accordingly – which can provide one element in an export control compliance program.

Toward a Financial Integrity Risk Management Program
This article explores the commonalities between AML, sanctions compliance, ABC, fraud risk management, and export control compliance programs and recommends that organizations consider using a holistic financial integrity risk management and compliance framework.

Webinar Recap – The Dos, Don’ts & Expert Insights on Beneficial Ownership
In our recent webinar, regulatory, investigative, and anticorruption policy experts discussed some of the nuances relating to the U.S. Corporate Transparency Act (CTA) and its Beneficial Ownership reporting requirement. Explore the highlights in this article.

Cold Turkey
Consumer spending over the holiday season is expected to top $1.66 trillion this year in the U.S. alone. This article describes five holiday season frauds to be aware of along with associated red flags to avoid being scammed.

The Sanctions Evasion Threat
It’s more important than ever for compliance officers to understand and recognize sanctions evasion typologies. In this article, we explore six of the most common techniques illicit actors use to evade sanctions.

How to be a Digital Asset Detective
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Side Quest
“Side quests” are initiatives that align staff motivations, interests, and experience with discretionary projects. They provide solutions to enhance staff engagement, performance, and retention, and are particularly valuable where resource constraints may slow promotions or pay increases, or where compliance tasks involve repetitive work.

Big Fines, Bigger Lessons
TD Bank’s $3 billion fine highlights a growing trend: regulators are cracking down hard on weak AML programs. Discover why fines are skyrocketing and how strong AML training can help safeguard your institution.

Risky Convergences
New digital solutions in money laundering and underground banking have facilitated the expansion of the criminal business environment in Southeast Asia, integrate billions of criminal proceeds into the formal financial system and enabling the growth of new criminal organizations.

A PEP Talk
Politically exposed persons are individuals who, due to their positions of power, influence, or proximity to government, are susceptible to becoming involved in corruption, bribery, or other financial crimes. And because moving and hiding misappropriated assets often involves money laundering, financial institutions across the globe are tasked with the challenge of identifying and managing these risks.

A $3 Billion Mistake
TD Bank was recently slammed with a record $3 billion fine for failing to comply with AML laws. With $18 trillion in unmonitored transactions, the bank became a hotbed for criminal activity. What went wrong, and what can other financial institutions learn from this?

Beneficial Ownership: Who Owns What?
U.S. efforts to curb illicit finance are in full swing, as the requirement to reveal the beneficial owners of certain entities registered or operating in the United States came into effect this year. In this article, we explore key requirements, benefits, and deadlines as well as address some of the concerns organizations may have about the new regulation.

From Cash to Clicks – AML Challenges & Typologies for Digital Payments
Dive into the dynamic world of digital payments, where convenience meets innovation. Learn the challenges Payment Service Providers are navigating with smarter, technology-driven Anti-Money Laundering practices to ensure secure and efficient transactions.

How has Terrorism Financing Changed Since 9/11?
While financial provisions enacted after the terrorist attacks of 9/11 have succeeded in addressing vulnerabilities in the global financial system, terrorist organizations have developed new methods of fundraising and moving assets, including digital assets and online platforms. In this article we examine how new technologies facilitate terrorism financing and the risks financial institutions should consider.

A Review of the Financial System Post 9/11
After the terrorist attacks on September 11, 2001, the private sector, especially financial institutions, began to play a vital part in protecting the U.S. and global financial systems. In this article we examine the changes to the financial system that resulted after 9/11 and discuss how the role of financial institutions has changed with respect to deterring and detecting the financing of terrorism.

AML Compliance for Small Businesses
Small businesses face the challenge of navigating the intricate landscape of anti-money laundering (AML) regulations. Despite the challenges posed by evolving global standards and limited resources, small businesses can use tailored strategies to fortify their compliance frameworks and thrive in a complex regulatory environment.

Collaboration Between Chinese Money Laundering Organizations & Drug Cartels
Global regulators are highlighting the growing threat of Chinese money laundering organizations that help transnational criminal organizations—particularly drug cartels—access and move assets through the global financial system. Global financial institutions must enhance their due diligence efforts, given the growing scope of the problem and the increasingly sophisticated methods used to launder drug proceeds.

Elevating Defenses
Dive into the cutting-edge strategies that financial institutions are implementing to combat the evolving threat of AI-driven fraud. From deploying advanced detection technologies to fostering robust networks of allies, learn how the financial sector is bolstering its defenses against sophisticated scams like deepfakes and biometric fraud.

Deepfakes and Dollars
While AI has the potential for transformative impact in the financial sector, it also introduces new challenges. From biometric mimicry to the alarming rise of deepfakes, this blog highlights emerging threats and challenges in countering AI-driven fraud.

Working Together to Fight Transnational Financial Crime
The transnational nature of criminal networks, cross-border financial flows, and sometimes the international nature of crimes themselves, mean a unified response between the public, private sector, and “third sector” is critical. This article uses the example of human trafficking to identify the capabilities of each sector and how they can achieve the greatest effect by working together.

The Convergence of Sanctions & AML
The convergence of sanctions and anti-money laundering efforts has significantly accelerated since Russia’s full-scale invasion of Ukraine in February 2022. FINTRAC in June 2024 released a special bulletin focusing on financial activity associated with suspected sanctions evasion. The report highlighted shared methodologies and insights to help compliance teams collaborate on best practices.

Three Lines of Defense: Case Study
The “three lines of defense” model is a widely recognized approach for effectively managing financial crime and regulatory risk. But how does it work in practice? This article explores how the three lines of defense applies using client due diligence as a real-life case study.

Crypto Under the Microscope
In the fast-evolving digital assets market, compliance is not just a regulatory requirement—it's a strategic imperative. From Binance's multi-billion-dollar settlement to the dramatic collapse of FTX, recent enforcement actions have sent shockwaves through the industry, underscoring the critical need for a robust compliance system.

Three Lines of Defense
The “three lines of defense” is a well-established model for implementing an organizational structure to effectively manage financial crime risk and regulatory compliance. Explore the three lines of defense, their responsibilities and the advantages of the three line model in this article.

Understanding and Addressing Fraud and Corruption Risks
In our recent webinar, industry experts delved into the crucial topic of fraud and corruption risks. From seasoned professionals to anti-corruption activists, the webinar featured a panel of distinguished speakers: Steve Burgess, Nikki Kenyon, Chris Williams, and James Wasserstrom. This blog post aims to summarize the key points discussed during the session, equipping readers with the knowledge necessary to navigate these risks effectively.

Embracing Emerging Technologies through Capability Development
Risk is perceived to be higher when a subject area is unfamiliar, which is particularly likely for emerging technologies and products. One solution is to develop the capability of staff through training and experience, where Chief Compliance Officers can utilize partners to support upskilling and augment internal capability where required. Digital assets provide a good case study: detailed knowledge within financial institution compliance and business teams to manage risks while enabling business growth.

Corruption in Construction
Corruption in the construction sector can include everything from fraud, to extortion, embezzlement, and other abuses. Corruption doesn’t just undermine good governance; it endangers lives and threatens the reputation of any financial institution involved in construction projects that are rife with fraud and abuse. How can government organizations and financial institutions mitigate corruption risks when funding or supporting infrastructure projects? How can they detect suspicious transactions?

OFAC’s Compliance Guidance in Action
The Treasury Department’s Office of Foreign Assets Control (OFAC) five years ago published its Framework for OFAC Compliance Commitments. This guidance remains the most comprehensive articulation of OFAC’s compliance expectations to date. Although it notably stopped short of mandating a sanctions compliance program (SCP), recent enforcement actions demonstrate the implications of not having an SCP in place.

Corruption Kills
Construction projects are especially vulnerable to corruption because of their complexity, high price tags, and the number of intermediaries and other parties involved. Corruption in the construction sector does not merely result in financial losses, environmental destruction, and inequality, but it can also result in loss of life.

FinCEN Issues Warning to Financial Institutions
Iran continues to explore techniques that allow it to move funds to terrorist proxy groups in its efforts to destabilize the Middle East and project power by supporting the global operations of dangerous militias, proliferation of weapons, and malicious cyber activities. Financial institutions must be increasingly vigilant in detecting illicit transactions linked to Iran-backed terrorist organizations. Regulators have providing guidance, including red flags, and highlighting methodologies used by terrorist groups to raise funds.

2024 National Proliferation Financing Risk Assessment
The U.S. Department of the Treasury published the 2024 National Proliferation Financing Risk Assessment in February 2024 providing an in-depth analysis of the threats and vulnerabilities related to proliferation financing (PF) and highlighting key countries and non-state actors working to gain access to weapons of mass destruction (WMDs) and their components and to conventional restricted weapons and technologies.

Golden Visas & Global Graft – How Criminal Actors Exploit Citizenship by Investment Programs
While special naturalization programs offered in certain jurisdictions to foreign investors intend to attract foreign direct investment and economic and infrastructure development, these programs can be abused by criminals who seek to launder and conceal proceeds of crime or commit new offences, including financial crimes.

Are Casinos Havens for Money Laundering?
A recent UN Office on Drugs and Crime (UNODC) report has found that casinos, junkets, and cryptocurrencies are exacerbating transnational organized criminal activity in East and Southeast Asia as part of the region’s underground banking and money laundering infrastructure. Although the use of casinos to launder money is not new, the proliferation of online gambling since the COVID 19 pandemic has aggravated the existing problem and has given rise to underregulated online gambling venues as more gamblers began playing from home.

Risky Russia – Government Agencies Warn Businesses of Possible Trouble
The US Departments of State, Treasury, Commerce, and Labor in late February issued a business advisory warning firms and financial institutions about the serious legal, financial, and reputational risks of doing business in Russia. According to the State Department’s assessment, Russia’s kleptocratic environment undermines fair competition and the rule of law, exposing businesses to the risk of extortion, appropriation of assets, and US law enforcement action.

Pig Butchering on the Rise: When Romance Goes Wrong
What is pig butchering and how does it work? Read on to explore the global regulatory response to this rising scam, identify scam tactics and key mitigation strategies.

Real Estate in 2024 – Anticipating a Crackdown on Corruption & Fraud
Real estate in the United States has long been a popular channel for corrupt actors seeking to launder illicitly obtained funds. As part of the Biden administration’s 2021 Strategy on Countering Corruption, a long-awaited proposed rule from the Treasury Department that is slated to take effect in early 2024 will seek to address that glaring loophole in US anti-money laundering (AML) regulations.

What Financial Institutions Can Learn from the Binance Settlement
Explore lessons learned from the recent Binance settlement including risk mitigation strategies for banks and other financial institutions.

Binance Settles with Regulators
Binance, the world’s largest cryptocurrency exchange, on November 21st pleaded guilty and agreed to pay more than $4.3 billion to resolve the US Justice Department’s investigation into its violations of the Bank..

Cyber-Enabled Fraud
Cyber-enabled fraud (CEF) is growing, especially with increasing digitalization across the globe.
Technological advances have enabled cyber criminals to develop and increase the scale,
scope, and speed of their illicit activities.

Terrorist Use of Crowdfunding
The nature of crowdfunding, the use of new technologies, and the possible anonymity afforded by crowdfunding platforms can make them attractive as relatively quick and simply means to obtain donations from across the world.

Domestic Terrorism – Understanding the Threat and How Banks Can Counter It
Domestic terrorism is not a new threat in America, but in recent years we have seen a significant and horrific increase in violent attacks and activities carried out by individuals and groups motivated by a range of radical ideologies. In response to these troubling developments, our government has stepped up law enforcement, intelligence attention, and resources to combat these threats.


