Anti-Money Laundering

MEGAMINDS

80+ experts,
60+ hours
of conversation,
one report
Without collaboration
Foreword
and conversation,
we are nothing.

This report delves into over 60+ hours of

dialogue with 80+ experts from The Laundry
podcast.
What began as a simple opportunity for us the presenters to ask
questions and learn, has evolved into a valuable resource for listeners
across the industry.

The AML (Anti-Money Laundering) Megaminds report is the culmination

of these discussions with specialists from diverse backgrounds: Chief
Compliance Officers with extensive big bank experience, MLROs and
data scientists at the sharp edge of financial services, law enforcement
officers who have tracked down organised crime groups and brought them
to justice, investigative journalists exposing fraud and money laundering
in major newspapers, politicians pushing for change, and whistleblowers
courageous enough to stand up to corruption.

These varied life experiences weave a rich tapestry of perspectives, insights,

strategies, and trends. This report seeks to connect the dots, draw threads
between these conversations, and uncover the industry’s true opinions on
topics ranging from sanctions and regulation to emerging threats.

2 AML Megaminds Report First edition V1

Our aim was to harness these conversations to construct the ultimate
expert— deeply knowledgeable, drawing from multiple viewpoints,
and centuries of combined career experience.

Financial crime impacts every facet of our society; it corrupts, poisons,

and steals—then flaunts its ill-gotten wealth on our high streets and in
our leafy suburbs. Yet, the default position within the compliance
and AML industry has been to keep our strategies hidden.

Bluntly, this approach hasn’t worked. The United

Nations Office on Drugs and Crime estimates that
$800 billion to $2 trillion is laundered each year,
representing 2–5% of global GDP.

It’s time to open up, compare notes,

and figure out how we can do better.

Marit Rødevand
Strise CEO and
The Laundry host
Contents

Foreword2
An introduction from Strise CEO and The Laundry host, Marit Rødevand, on
why collaboration is the key to fighting financial crime and how this report
captures the knowledge of 80+ experts.

Lost in the 'Red tape jungle'?  6

Key insights8
70% believe AML measures are inefficient, while 40% think sanctions
aren’t working. Explore expert views on the need for smarter, more effective
strategies in the fight against financial crime.

40% believe sanctions are not working 9

35% believe the financial industry is over-regulated 13

70% believe current AML measures are inefficient 17

70% of AML experts see legacy systems as a major barrier 21

70% of AML experts optimistic about AI's impact 24

What makes the boardroom care about AML compliance? 26

The top 5 money laundering hotspot 30

AML tales35
Step into the world of financial crime with gripping stories shared by AML
experts. From high-flying cash smugglers to state-backed hackers and real
estate schemes.

5 shocking AML tales told in the podcast 36

Compliance missteps40
Even the pros get it wrong. Find out the top 10 mistakes in AML compliance
that could leave your business exposed to financial crime.

Top 5 AML compliance missteps 41

Fincrime trends 2025 and beyond  44

What’s next in financial crime? Learn about the rising threats for 2025
and beyond, from AI-enabled fraud to deepfakes.

Predictions for the future of financial crime 45

Radical solutions  51

Methodology54

A thank you 55

About Strise 56

Anti-Money Laundering Megaminds 57

 Lost in the
'Red tape jungle'?
From navigating the ‘Red Tape Jungle’ to dodging
‘Regulatory Whiplash,’ these are the terms our guests
use to bring some humour to the serious business
of compliance. Let’s dive into the most memorable
ones!

“Red tape jungle”: used to describe the complex and

overwhelming regulatory environment that professionals have
to navigate.

“Compliance theatre”: term used to refer to the act of

going through the motions of compliance without any real
substance.

“The compliance hamster wheel”: the repetitive and

exhausting nature of the ongoing and endless compliance tasks.

“Regulatory spaghetti”: the tangled mess of overlapping

regulations that compliance professionals have to deal with.

6 AML Megaminds Report First edition V1

 “Financial crime Disneyland”: jurisdictions or sectors
that are seen as particularly attractive or easy for financial
criminals to operate in.

“Regulatory whiplash”: of trying to keep up with rapidly

changing regulations.

“Snake oil schemes”: fraudulent investment schemes or

scams that are deceptively marketed.

“The loophole express”: the swift exploitation of legal

loopholes.

“Paper tiger”: a law or regulation that appears strong but is

actually weak or ineffective in practice.

7 AML Megaminds Report First edition V1

"I've never yet met a criminal who only does
one thing. Criminals don't operate in silos.
Banks shouldn't operate in silos."

Key
insights
40% believe sanctions
are not working
The effectiveness of sanctions has sparked a range of
opinions among contributors. Below is a comparative
analysis of the different perspectives gathered by the
AML Megamind on the efficacy of sanctions.

Sanctions are working as intended

Some experts expressed strong confidence in the effectiveness of sanctions,
particularly in their ability to disrupt financial networks and apply economic
pressure on targeted individuals or entities. They cited specific cases, such as
the freezing of Russian assets and the impact on oligarchs, as clear examples
of sanctions achieving their intended outcomes. From this perspective,
sanctions are a crucial tool in the international community’s arsenal,
effectively cutting off access to financial systems and forcing concessions
from those targeted.

Sanctions are not fully effective

Others took a more critical view of the current regime, arguing that while they
may disrupt certain activities, they often fail to achieve broader geopolitical
aims, such as ending conflicts or effecting regime change. They noted that
sanctions might prove effective in the short term, but their long-term impact
is limited. Concerns were raised about “sanctions fatigue”, where prolonged
measures lose their potency, and the unintended consequences, such as
harm to civilians or driving illicit activities underground.

“Sanctions may disrupt financial networks, but they often fail to accomplish the
larger political goals.”

9 AML Megaminds Report First edition V1

 40 %
Sa

ct
n

io
ns
no xed views
tw % Mi
o 28
rk
in
g

32%
S a n ct
ions w
or k i
ng

Belief in the effectiveness

of sanctions among AML
Megaminds

10 AML Megaminds Report First edition V1

 Mixed views on sanctions effectiveness
Some recognised that while sanctions are an important tool for applying
pressure, they are not a cure-all. The effectiveness of sanctions depends
heavily on enforcement and multilateral cooperation. They also advocated
for more sophisticated, targeted sanctions that could be better tailored to
specific situations to minimise collateral damage and maximise their impact.

“Sanctions are necessary, but they’re not a silver bullet. We need better
enforcement and more targeted strategies to enhance their effectiveness.”

The main dividing line is the perceived effectiveness of sanctions. While

some believe they are working as intended, others argue they fall short of
achieving broader political objectives and may even backfire. This mix of
opinions suggests that success is contingent on factors such as enforcement,
innovation, and international cooperation.

This debate highlights the need for ongoing innovation in sanctions policy,
better enforcement mechanisms, and more nuanced approaches to ensure
that sanctions are both effective and sustainable in the long term.

Sanction screening is necessary

Many emphasised the importance of sanction screening as a fundamental
tool for preventing financial crime. They argued that effective screening
processes are essential for identifying and blocking transactions involving
sanctioned individuals or entities.

Many AML Megaminds highlighted the role of technology in improving

the accuracy and efficiency of screening systems, reducing false
positives, and ensuring that financial institutions remain compliant
with regulatory requirements.

11 AML Megaminds Report First edition V1

"Sanctions are a puzzle—criminals find
one missing piece, and they exploit it."

“Sanction screening is a critical tool in the compliance toolkit. With the right
technology, we can significantly reduce false positives and ensure we catch
the bad actors without hindering legitimate transactions.”

Challenges and limitations of sanction screening

Some noted that while screening is necessary, it still often results in a high
volume of false positives, which can overwhelm compliance teams and cause
unnecessary delays for legitimate transactions. They also highlighted the
difficulty of keeping screening systems up-to-date with constantly changing
sanctions lists, which can create gaps in coverage and pose potential
compliance risks.

“Sanction screening is necessary, but the volume of false positives can be

overwhelming. Keeping up with constantly changing sanctions lists is another
challenge, creating gaps that bad actors could exploit.”

The need for smarter sanction screening

The divergence lies primarily in the perceived effectiveness of current
screening systems, with the suggestion being that while sanction screening
is indispensable, it requires ongoing innovation and refinement to address
its limitations.

This conflict points to the need for smarter, more targeted screening
processes that can better handle the complexities of modern financial
systems while minimising the burden on compliance teams. Advances
in technology and analytics will be key to achieving these improvements,
ensuring that sanction screening remains a vital and effective tool in the
AML arsenal.

12 AML Megaminds Report First edition V1

35% believe the financial
industry is over-regulated
In many episodes of The Laundry, AML Megaminds
shared their views on the topic of over-regulation
within the industry – revealing a nuanced debate
that demonstrates the challenges and necessities of
the current regulatory environment.

Positive Sentiment (65%): Many believe that regulations are essential and
have contributed to a more robust system for preventing financial crime.

But more intriguing is the significant percentage of experts who share a less
favourable view of regulations.

Negative Sentiment (35%): A portion expressed concerns that the industry

is over-regulated, leading to inefficiency and a “tick-box” mentality.

EU concerns
One expert voiced significant concerns about over-regulation regarding the
detailed and prescriptive nature of EU regulations.

13 First edition V1
 35% Negative sentiment
Is the financial sector
over-regulated?
65%
Positive sentiment
Experts weigh in.

They argued that an excessive focus on tick-box compliance could detract from
a more holistic, risk-based approach to AML, potentially causing institutions
to focus too narrowly on meeting specific requirements and overlook broader
cultural and ethical compliance aspects.

“Sometimes I think the AML area is over-regulated. There’s a risk that you miss
these cultural issues and your gut feeling.”

The case for stringency

In contrast, others emphasised the necessity of stringent regulations,
especially given the current geopolitical climate involving tensions with

14 AML Megaminds Report First edition V1

 countries like Russia, Iran, and others. While acknowledging the complexity
and burden of compliance, they argue that these regulations are crucial
for maintaining integrity and preventing financial crime, particularly in the
context of sanctions.

“The regulations are what ensure that we’re all playing by the same rules,
especially in such a dynamic geopolitical environment.”

Spending
Concerns were also raised about whether the industry’s current focus
is yielding the desired results, suggesting that while investment in AML
compliance is necessary, it might not always be efficiently allocated due
to regulatory burdens.

“We’ve spent money, but has it been spent in the right place? Probably not.
We can do better with the same money and get more efficient results.”

Limitations
Additional perspectives highlighted the impact of regulation on innovation
and its global applicability. Some experts criticised the regulatory
environment for stifling innovation, particularly for fintech startups that
struggle with high compliance costs.

“The regulatory framework is built for large institutions, but it’s the smaller,
innovative companies that are often left struggling under the weight of
compliance requirements. This stifles innovation and could ultimately harm
the industry’s ability to evolve.”

Some also pointed out the Western-centric nature of current regulations,

suggesting that a one-size-fits-all approach can be counterproductive,
especially in emerging markets.

15 AML Megaminds Report First edition V1

"Every new AML regulation is like a plot twist in a
crime thriller—just when you think you’ve got it
figured out, there’s a new surprise."

“We’re applying Western standards globally, but the risks and financial systems
in emerging markets are different. By not adapting regulations to local contexts,
we might be driving financial activity underground, where it’s harder to monitor
and control.”

The industry faces the challenge of navigating this complex regulatory

landscape while striving for effective, risk-based compliance practices
that go beyond mere box-ticking. Striking this balance is critical to ensuring
that AML efforts are both efficient and successful in mitigating financial
crime globally.

16 AML Megaminds Report First edition V1

70% believe current AML
measures are inefficient
The effectiveness of current AML efforts has been
hotly debated among guests of The Laundry. Despite
significant investments in technologies, personnel,
and processes, there is a widespread feeling that
these efforts are not achieving the desired results.

Many have expressed concerns about the efficiency of existing AML

frameworks and their capability to combat financial crime effectively.

70% believe that current AML measures are inefficient, with only a small
fraction of money laundering activities being detected and stopped.

30% hold a more optimistic view, suggesting that while challenges exist,
progress is being made.

This divide underscores a critical debate within the financial sector:

Is the current approach to AML truly effective, or are we merely scratching
the surface of a deeper issue?

17 AML Megaminds Report First edition V1

 tic view
mis
pt i
%o
30
nt
cie
effi
L measures are in
AM

Experts weigh in on the

%

efficiency of current
70

AML measures

18 AML Megaminds Report First edition V1

 Limited impact of investments
A recurring theme is that despite substantial financial investments in
AML compliance, the return in terms of actual crime prevention remains low.

“Europol’s figure that only 1% of laundered money is actually stopped

underscores the grim reality that current AML efforts are not as effective as
intended. Despite our best efforts, the results show we are only scratching
the surface when it comes to preventing money laundering.”

Experience and misaligned strategies

Others noted that a key reason for this inefficiency is the “competence
gap” in the AML field. The rapid expansion of AML operations has created
a shortage of experienced personnel, leading to a box-ticking mentality
rather than a proactive, risk-based approach. Emphasis often remains on
meeting regulatory requirements rather than developing a comprehensive
understanding of money laundering tactics and enhancing detection
capabilities.

Fragmented data and siloed operations

Experts also highlighted the challenge posed by fragmented data and siloed
operations within financial institutions. This fragmentation hinders the ability
to view the full scope of financial transactions, thereby undermining the
effectiveness of AML efforts.

One specialist emphasised that “availability and quality of data are key issues”
and called for a more holistic approach to financial crime prevention.

Data sharing between different departments within the same organisation

and across different institutions is severely limited due to privacy regulations
like GDPR. This restriction hampers the ability to build comprehensive

19 AML Megaminds Report First edition V1

 profiles and track illicit activities effectively. Some discussed the need for
improved internal collaboration and data sharing to prevent fraud and money
laundering more effectively​.

“The fragmentation of data and lack of integration across financial institutions

makes our AML efforts feel like a losing battle.”

A self-critical industry
The sentiment among experts is overwhelmingly critical of the current
state of AML efforts.

Despite substantial investments and regulatory pressures, the effectiveness

of these efforts remains questionable. To enhance the impact of AML
strategies, there needs to be a tectonic shift towards more dynamic,
data-driven approaches that leverage technology and foster cross-
institutional collaboration. By doing so, the financial sector can better
anticipate and counteract the evolving tactics of financial criminals.

“We don’t know the criminals as well as we should; we’re always lagging behind.
A checkbox mentality doesn’t cover the risk-based approach that the regulators
emphasise”​.

20 AML Megaminds Report First edition V1

70% of AML experts see
legacy systems as a
major barrier
With the rapid evolution of our technology, regulatory
requirements and directives are also becoming more
stringent. Concurrently, transaction volumes in the
market are increasing. Organisations must navigate
these simultaneous changes.

Many financial institutions still rely on outdated technology and manual

processes, which are inadequate to counter the sophisticated methods
employed by modern criminals. There is a need for better integration of
advanced technologies, such as artificial intelligence and machine
learning, to enhance predictive capabilities and reduce false positives.

“Relying on outdated technology is like bringing a knife to a gunfight.

Without integrating advanced AI and machine learning, we’re just not equipped
to detect and prevent sophisticated financial crimes.”

Financial institutions must evaluate their capabilities while maintaining a

consistent risk-based approach. This requires adopting new tools equipped
with APIs that gather information on customer behaviour and identify
non-conforming actions.

In addressing technological challenges in AML compliance, lawmakers

and regulators could further enhance unique beneficiary owner registers
and improve access and data verification through APIs.

21 AML Megaminds Report First edition V1

 Challenges of Legacy t
Systems in AML Efforts i fic an
Discussed by Experts si gn

t
No
10 %
able
n age
M a
%

20

ie r
barr
r
M a jo
0%
7

The general sentiment among the experts regarding the pace of technological
change and its impact on legacy systems in AML is cautiously optimistic but
acknowledges significant challenges.

22 AML Megaminds Report First edition V1

 Optimism for new technology
Industry professionals are generally optimistic about the potential of new
technologies like AI and machine learning to revolutionise AML practices.
They believe these technologies can significantly enhance AML efforts,
particularly in automating tasks and improving the accuracy of monitoring
and reporting systems.

Challenges with legacy systems

However, there is widespread recognition that legacy systems pose a major
barrier to fully realising these technological advancements. Legacy systems
are often seen as cumbersome, fragmented, and difficult to integrate with
new technologies, creating significant bottlenecks, especially
when implementing modern solutions over outdated infrastructure.

Need for incremental change

Experts advocate for a cautious approach to replacing legacy systems,
stressing the importance of incremental improvements rather than
large-scale overhauls. This method helps manage risks and ensures
continuity in AML compliance efforts while gradually integrating new
technologies.

23 AML Megaminds Report First edition V1

70% of AML experts
optimistic about AI's impact
70% Optimistic: A significant majority are optimistic
about integrating AI into their work—seeing AI
as a valuable tool that can enhance efficiency by
automating repetitive tasks, improving alert systems,
and supporting decision-making processes, allowing
experts to concentrate on more complex financial
crime prevention activities.

“We could reach a point where everyone has a co-pilot... We could get to a
stage where essentially everyone becomes a risk manager, monitoring all
client interactions in real time. I think that could be a real positive for financial
crime compliance.”​

20% Neutral or uncertain: Approximately 20% have a neutral or uncertain

perspective on AI’s role in AML. While they recognise the potential
advantages, they are cautious about the technology’s current limitations
and emphasise the necessity for robust oversight to avoid errors and biases
in AI-generated outcomes.

“Fully integrated AI? I don’t think we’re there yet, at least not to the extent
people would like... But I think that will change quickly now with
developments like OpenAI.”​

10% Pessimistic: A smaller group is pessimistic about AI in AML.

They express concerns that an over-reliance on AI might undermine human
judgement and expertise. These experts worry about the risks associated

24 AML Megaminds Report First edition V1

 u t AI
ic abo
Experts weigh is t
m
opportunities and si

s
challenges of AI in

Pe
10 %
AML efforts
U ncertain
t r a l or
u
Ne
%

20

t AI
bou
ca
i sti
t im
Op
70 %

with AI, including potential errors, lack of transparency, and ethical issues
related to data usage and privacy.

“You need to really be mindful of how you apply this because if you’re using some
black box AI to make decisions... The more black box AI becomes, the harder it
will be to reason about those decisions.”​

25 AML Megaminds Report First edition V1

What makes the
boardroom care about
AML compliance?
Preventing financial crime is a strategic priority that
must be driven by senior management and the board.
The AML Megamind has identified key factors that
compel leadership to focus on compliance and crime
prevention.

Regulatory pressure and compliance

Around 35% of experts emphasised regulatory pressure as a crucial factor in
making financial crime prevention a priority at the senior management level.

The risk of non-compliance with AML regulations and the associated

penalties often compel boards to focus on this issue.

“The risk that compliance officers face is not money laundering; it’s being
prosecuted by the DOJ. That’s the problem. It’s not about stopping money
laundering; it’s about not facing a nine-figure fine from the DOJ. The incentive
is avoiding fines, not effectively preventing money laundering”​.

Reputation and public perception

Approximately 25% underscored the significance of reputation management
in prompting board-level focus on preventing financial crime.

Some noted that scandals involving financial crime can have enduring
impacts on a company’s brand and erode customer trust, which makes it
crucial for boards to adopt proactive measures.

26 AML Megaminds Report First edition V1

 35%

30%

25%

20%

15%

10%

5% Factors driving financial

crime prevention to
senior management
and board-level issue
ctations
o n a l task
ressure

Legal liability

ct
nal impa
to r y p

xpe
u t at i

atio

r e
g ula

lde
Re p

Shareho
e
Op
Re

“The Swedbank case, which unfolded between February 2019 and April 2019, led
to a 30 percent drop in their share price due to uncovered non-compliance with
AML regulations. Similarly, Danske Bank saw a dramatic 60 percent decline in its
share price following revelations of money laundering breaches.”

The direct financial consequences of failing to prevent financial crime,

including losses from fraud, legal costs, and the impact on share prices, were
also frequently mentioned. About 20% of the experts focused on the financial
implications as a key reason for senior management involvement.

27 AML Megaminds Report First edition V1

 Strategic importance and competitive advantage
Companies recognised as leaders in compliance can distinguish
themselves in the market, which can subsequently drive board-level
engagement and interest.

This was less frequently mentioned, accounting for approximately 15%

of the mentions, but is considered crucial by those who view AML as a
strategic priority.

AML perspectives on boards

AML experts emphasise the importance of fostering a top-down culture
of compliance, where senior management sets a clear tone that prioritises
financial crime prevention. Having board members with specific expertise in
financial crime and compliance ensures these issues receive the necessary
attention and strategic focus.

“We need more people on boards who aren’t from banking backgrounds—perhaps
more police, tax experts, or other outsiders who bring a diverse perspective.
We don’t know the criminals as well as we should; we’re always lagging behind.”

Many expressed that senior management and the board must visibly commit
to compliance, demonstrating that financial crime prevention is a priority.
Without clear leadership and communication, compliance efforts may falter,
as employees tend to mirror management’s commitment.

A robust compliance culture is key to effective financial crime prevention.

This requires continuous education, open communication, and early
involvement of compliance teams in decision-making processes.
Compliance should be seen as a partner in business operations, not merely
as an overseer.

28 AML Megaminds Report First edition V1

 Practical tips from the experts
• Visible support from leadership: Leaders must regularly
demonstrate their commitment to compliance, not just
through policies but through active participation in compliance
initiatives and public declarations.

• Early involvement of compliance teams: Involving compliance

teams early in business processes allows for proactive guidance,
ensuring decisions align with regulatory requirements.

• Creating open communication channels: Establishing open

communication between compliance teams and the broader
organisation helps foster a supportive environment where
compliance is seen as collaborative rather than punitive.

• Training and continuous learning: Regular, engaging training

programmes are crucial to help employees understand the rules
and the rationale behind them, highlighting the importance of
preventing financial crime and protecting the organisation’s
reputation.

• Encouraging a speak-up culture: A culture where employees

feel safe to report concerns or suspicious activities is vital. This
can be achieved by implementing clear policies, protecting
whistleblowers, and ensuring management responds
appropriately to all reports.

“One of our core principles is the ‘early bird approach,’ which invites everyone in
the organisation to involve risk and compliance early in all processes. I always
tell my colleagues, ‘Give me a chance to say yes instead of no; ask me early.
’ My experience has shown that the later you involve risk and compliance, the
more likely you are to get a ‘no.’ Early involvement allows us to guide decisions
in a compliant manner from the start.”​, says one of the experts.

29 AML Megaminds Report First edition V1

The top 5 money
laundering hotspots
Throughout The Laundry, certain industries have
repeatedly emerged as high-risk hotspots for money
laundering. These sectors are frequently exploited
by criminals to launder illicit funds. Based on
insights from experts, this section delves into why
these industries are so vulnerable and the unique
challenges they pose.
Here is the experts reasoning why certain industries and sectors
are particularly susceptible to money laundering.

1. Real estate
Real estate is a preferred channel for money laundering because
it allows criminals to convert large amounts of illicit cash into
legitimate assets. The process of buying and selling properties
offers a convenient method to integrate dirty money into the
financial system, often with minimal oversight. This is especially
true when properties are acquired through shell companies or
offshore entities, which obscure the true ownership.

“The use of shell companies and fake identities in property

transactions obscures the real ownership and creates a
perfect avenue for laundering large sums of money. The lack of
transparency and oversight makes it easy for criminals to exploit
these loopholes”​.

30 AML Megaminds Report First edition V1

 “For many years, oligarchs and others have been purchasing
property in the UK while keeping their ownership hidden.
They achieve this by owning properties through offshore shell
companies registered in places like the British Virgin Islands
or Liberia, effectively concealing their identities and avoiding
public scrutiny.”
Re

es
al

tat
e

Fin a
ncial S
ervices

Luxury Goods

ncy
Cryptocurre

Casi nos
b ling &
G am
s
uitie
A ntiq
&
Art Fashion)
h -End
Hig
t ail (
Re
on
u cti
tr (Lawyers, Accountants)
ons v ices
C er
lS
na

5% 10% 15% 20% 25%

sio
fes
Pro

Experts highlight sectors most vulnerable to money laundering

2. Financial Services
Financial services are central to most money laundering
schemes due to the sector’s vast transaction volumes and
global reach. Banks and financial institutions are frequently
targeted by money launderers who exploit weaknesses in AML
controls to move illicit funds across borders. Despite robust
regulatory frameworks, compliance gaps and the inherent
complexity of financial transactions make this sector vulnerable.

31 AML Megaminds Report First edition V1

 Compliance officers acknowledge that while banks have
improved their transaction monitoring capabilities, the intricate
nature of modern financial systems still allows for substantial
laundering activities, particularly through mechanisms like
trade finance and correspondent banking.

“AML and compliance workers in banks have been one of the

fastest-growing professions over the last few years... It’s a constant
chase due to the rapidly evolving nature of financial crimes and the
complexity of maintaining compliance​.”

3. Luxury goods
The luxury goods market—including high-end art, jewellery,
and vehicles—is a common avenue for money laundering.
These high-value items can be purchased with illicit funds
and later sold or transferred, effectively “cleaning” the money.
The subjective valuation of luxury goods complicates efforts
to detect laundering activities.

Experts point out that the ease of transporting luxury items

and their subjective value make them appealing for laundering.
Art markets are especially vulnerable due to the anonymity of
transactions and the lack of stringent reporting requirements.

“In the art market, you often have an anonymous seller, an

anonymous buyer, and a brokerage house that sets the value.
This creates an environment where you can trade items much
faster and with far less oversight than traditional markets, leading
to a completely unpredictable price that can fluctuate dramatically
with each transaction. This volatility and lack of transparency
make it an ideal avenue for laundering money”​.

32 AML Megaminds Report First edition V1

 4. Cryptocurrency
Cryptocurrencies provide a level of anonymity and difficulty in
tracing that is highly attractive to money launderers.
The use of mixing services and decentralised finance (DeFi)
platforms to obscure the origins of funds is increasingly
prevalent. Furthermore, evolving regulatory frameworks
around cryptocurrencies contribute to the risk.

Cryptocurrency experts highlight the growing use of DeFi

and mixers in laundering activities, pointing out the significant
challenges regulators face in keeping pace with the rapidly
changing landscape of digital assets.

“Criminals are turning to Decentralized finance (DeFi) platforms

as one stage in the money laundering process. Mixers are also
increasingly popular destinations for illicit funds because they
obscure the origins, making it harder for blockchain analysis
to trace transactions. The technology evolves so quickly that
regulators and compliance teams struggle to keep up”​.

5. Gambling & casinos

Casinos and online gambling platforms are traditionally linked
to money laundering due to their cash-intensive operations.
Criminals can easily exchange large amounts of money for chips,
engage in minimal-risk gambling, and then cash out
as “winnings,” thereby laundering their funds.

AML experts note that the gambling sector, especially online

casinos, remains high-risk because it allows for the easy
layering and integration of illicit funds into the financial system
with minimal oversight.

33 AML Megaminds Report First edition V1

“Behind every data point is a human story
—our job is to find it and understand it."

“If I were to launder money, the casino gaming industry, which is

estimated to be several hundred billion dollars in market value,
would be ideal. You could enter with a lot of cash, buy poker chips,
make a few dummy bets with minimal risk, and then cash out
almost the same amount, or even more if you’re lucky,
as ‘winnings.’ This money then appears clean, especially when
taken out in the form of a cheque”​.

These sectors are considered high risk due to inherent

characteristics that facilitate the laundering of illicit funds.
Factors such as lack of transparency, ease of converting assets,
and the rapid processing of transactions make these industries
particularly vulnerable to financial crime. By understanding
these risks, organisations can better implement targeted
strategies to combat money laundering effectively.

34 AML Megaminds Report First edition V1

"The internet is the new Wild West for criminals,
and we're the sheriffs trying to bring law to the
digital frontier."

AML
tales
5 shocking AML tales
told in the podcast
Throughout the podcast, many guests have shared
captivating stories that reveal the innovative tactics
criminals use to exploit various industries and evade
detection. Here are five of the most stand-out stories
from the experts:

1. Stockholm’s lax exchange bureaus

In 2022, Sweden was shaken by a scandal involving a network of
exchange bureaus laundering millions of dollars in drug money,
with some funds reportedly diverted to terrorist organisations.
The epicentre of this scandal was a single exchange bureau in
Stockholm, which exploited significant weaknesses in Sweden’s
regulatory framework.

“It wasn’t just a failure of oversight, but a systemic misuse of a

weak regulatory environment that allowed these companies to
become active tools for laundering money. They were not just
slipping through cracks—they were operating with the knowledge
that nobody was watching.”

This scandal forced Swedish regulators to re-evaluate their

anti-money laundering frameworks, which were found
inadequate to combat sophisticated laundering techniques.
The breadth of the implicated network—34 out of 43 exchange
offices—revealed deep-seated issues within the regulatory
environment.

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 The impact went beyond Sweden, serving as a wake-up call for
the global financial community to strengthen AML controls
and enhance international cooperation.

2. Diamonds in the shadows

The global diamond trade, with its high value and portability,
became the centrepiece of an international money laundering
network. Criminals exploited the opaque nature of the diamond
market to move funds across borders, selling these stones to
unsuspecting buyers and funnelling the proceeds through a
web of shell companies.

This operation used various methods, such as over- and

under-invoicing, misrepresenting the quality and origin of
stones, and creating phantom trades. The involvement of figures
like Nazem Ahmad, who allegedly used diamond sales to fund
terrorist activities, underscores the severe risks associated with
such high-value commodities.

This case highlighted the evolving tactics of money launderers

who use commodities beyond traditional banking channels to
clean dirty money.

3. High-flying cash laundering

One of the boldest schemes to come to light involved criminals
using private jets to smuggle vast amounts of cash across
international borders. This operation showcased the audacity
of criminals leveraging high-value assets and exclusive travel
to evade detection. Private jets allowed these criminals to
bypass the scrutiny associated with commercial flights, taking
advantage of less rigorous oversight at private airstrips.

37 AML Megaminds Report First edition V1

 Once landed, the cash was quickly converted into real estate,
luxury goods, or funnelled through local businesses, effectively
laundering the money.

4. Turning a blind eye in the Caribbean

A major bank in the Caribbean became the focal point of a
bribery scandal, where officials were paid off to overlook
suspicious transactions. This allowed significant sums of illicit
money to flow through the bank undetected.

“They had entire departments turning a blind eye to obvious

signs of money laundering,”

The scandal was part of a broader pattern of financial crimes

in the Caribbean, where weak regulatory environments and
systemic issues in banking oversight have been exploited by
money launderers.

5. Rise of state-backed gangsters

A growing concern in the world of financial crime is the
emergence of state-backed criminals who blur the lines
between traditional criminal networks and state-sponsored
activities. One striking example discussed on the podcast is
the case of North Korean hackers who managed to steal over
$2 billion in cash and cryptocurrency assets. These hackers,
operating under state direction, leverage sophisticated cyber
tactics to fund their country’s regime, creating a unique
challenge for AML professionals and law enforcement.

This development highlights the evolving landscape of state

actors using advanced techniques traditionally associated
with organised crime to achieve geopolitical objectives.

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"Money launderers are like water—they
find the path of least resistance."

This introduces new complexities in tracking and combating

money laundering, requiring enhanced international cooperation
and innovative approaches to law enforcement.

This represents a significant challenge for the global community,

as it necessitates rethinking strategies and expanding the
scope of AML efforts to address both non-state and
state-sponsored threats.

39 AML Megaminds Report First edition V1

“Finding a money launderer is like finding a needle in a
haystack, except someone set fire to the haystack.”

Compliance
missteps
Top 5 AML compliance
missteps
Understanding the most common pitfalls in AML
compliance is crucial for financial institutions
seeking to protect themselves against financial
crime. These are the top 5 AML compliance missteps
most frequently discussed on the podcast.

1. Insufficient background checks and KYC/B

processes
One of the most frequently discussed compliance missteps
is the failure to conduct thorough background checks, robust
Know Your Customer (KYC) and Know Your Business (KYB)
processes. Many institutions do not gather enough information
about their customers, missing key indicators of potential risk.
A lack of thoroughness in verifying identities, understanding
the customer’s business, and assessing their risk profiles leaves
institutions vulnerable to money laundering activities.

Often, institutions rely on outdated or incomplete data, leading

to a false sense of security. There is also a tendency to focus
more on onboarding than on continuous monitoring, which is
essential for detecting changes in customer behaviour that
may indicate risk.

“It’s not just about checking a name against a list; it’s about
understanding the customer’s entire profile and the context of their
activities. Failing to do so is like welcoming a wolf into the fold.”

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 2. Inadequate due diligence on third parties
Institutions often overlook the importance of conducting
comprehensive due diligence on their vendors, failing to assess
their compliance with AML standards. This oversight can allow
money laundering activities to go undetected.

The complexity of global supply chains and increasing reliance

on third-party services demand a more robust approach to
vendor management. Institutions must ensure that vendors
adhere to the same AML standards and controls, which
includes periodic reviews and audits.

“Your compliance is only as strong as your weakest link, and that

includes your vendors. If they aren’t compliant, neither are you.”

3. Failure to identify Politically Exposed Persons (PEPs)

PEPs are considered high-risk due to their potential involvement
in corruption or bribery. Failing to properly identify and monitor
PEPs is a critical lapse in AML compliance. Many institutions
lack the necessary systems or expertise to detect PEPs, or they
do not perform sufficient due diligence once a PEP is identified.

The challenge lies in both identifying PEPs and assessing the

risks they pose. Institutions need to implement enhanced due
diligence measures for PEPs, including understanding their
source of wealth and monitoring their transactions more closely.

“PEPs aren’t just any customer; they come with additional risks that
must be managed diligently. Identifying them is only the first step;
understanding their transactions and associations is where the real
work begins.”

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 4. Lack of continuous monitoring of high-risk accounts
High-risk accounts require continuous monitoring to detect any
suspicious activities promptly. However, many institutions fail
to implement adequate monitoring systems or do not allocate
sufficient resources to track high-risk accounts, leading to
delayed detection of potential money laundering.

Effective monitoring involves not just tracking transactions but

also understanding customer behaviour patterns. Institutions
need to invest in advanced analytics and machine learning
tools that can identify anomalies and trigger alerts for further
investigation.

“High-risk accounts are high-risk for a reason. You can’t just set it
and forget it. Continuous monitoring is essential to stay ahead of
financial criminals.”

5. Failure to update systems and processes for

emerging threats
The landscape of financial crime is continually evolving, with new
threats emerging regularly. Institutions that fail to update their
systems and processes accordingly are at risk of being exploited
by these new methods of money laundering.

Institutions need to invest in research, training, and technology

that can adapt to new challenges and ensure their defences are
always up to date.

“Financial crime doesn’t stand still, and neither should we.

Our systems need to evolve constantly to stay one step ahead.”

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Fincrime
trends
2025 and
beyond
Predictions for the future
of financial crime
As financial crime evolves alongside technological
advancements and shifting global dynamics, it is
crucial for financial institutions, regulators, and law
enforcement agencies to stay ahead of emerging
threats. The following highlights the top financial
crime trends, as identified by the specialists.

1. Evolution of sanction evasion techniques

Criminals are continuously developing more sophisticated
methods to evade sanctions, leveraging decentralised finance
(DeFi) platforms and less regulated cryptocurrencies. These
advancements present significant challenges for monitoring
and enforcement. Enhanced monitoring capabilities and
AI-driven tools are becoming crucial to detect unusual patterns
that may indicate evasion.

“Key actors have been using cryptocurrencies and DeFi platforms to

evade sanctions, showcasing the adaptability of criminal networks
in bypassing regulatory scrutiny”

2. Emergence of Financial Crime as a Service (FCaaS)

The rise of Financial Crime as a Service (FCaaS) is
democratising access to sophisticated crime techniques by
offering tools and expertise for a fee. This trend increases the

45 AML Megaminds Report First edition V1

 frequency and complexity of financial crimes, necessitating
heightened vigilance from financial institutions and the
integration of intelligence-sharing networks with law
enforcement agencies.

“The accessibility of criminal tools on the dark web has

made it easier for inexperienced criminals to launch complex
financial crimes”

3. Rise of money mules and smurfing techniques

Money mules and smurfing techniques, which involve
breaking down large transactions into smaller ones to evade
detection, are on the rise. These methods exploit existing
AML frameworks, making it crucial for financial institutions to
enhance transaction monitoring and conduct public education
campaigns.

“The use of money mules and smurfing is not just increasing but
becoming more sophisticated, complicating detection efforts”

4. Increased focus on real estate and high-value assets

Real estate and high-value assets remain attractive for
laundering money due to their high value and the opaque nature
of transactions. This trend is driven by the ability to easily
integrate illicit funds into legitimate assets. To mitigate these
risks, stricter due diligence processes and ownership disclosure
requirements are essential.

“High-value assets provide a veneer of legitimacy to illicit funds,

making it a preferred method for laundering money. Enhanced
scrutiny in these sectors is critical”

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 5. Increased collaboration between financial
institutions and regulators
Greater collaboration between financial institutions and
regulators will be essential for combating financial crime
through shared intelligence and best practices. This approach
helps ensure a coordinated response to emerging threats.

“Collaboration is key. Sharing intelligence and best practices

can significantly enhance our ability to combat financial crime
effectively,” stated a regulatory affairs specialist.

6. Shift towards preventive, real-time monitoring

There will be a shift from reactive to preventive measures,
emphasising real-time monitoring systems that detect
suspicious activities as they occur. This proactive approach
is vital for staying ahead of financial criminals.

“The future of financial crime prevention lies in real-time monitoring

and proactive measures, rather than reacting after the fact”

7. Rise in synthetic identity fraud and digital twins

Synthetic identity fraud, where criminals create fake identities
using real and fabricated information, is expected to rise. This
type of fraud presents unique challenges for detection systems,
requiring innovative approaches.

“Synthetic identity fraud is difficult to detect because it combines

real and fake elements, requiring more advanced detection
methods,” explained an identity theft specialist.

47 AML Megaminds Report First edition V1

 Digital twins, virtual replicas of physical entities or systems, are
being used to simulate fraud scenarios, allowing criminals to
test tactics before execution. This technology is challenging to
detect and counter, requiring advanced monitoring systems.

“Digital twins provide a playground for criminals to test out

different fraud scenarios without real-world consequences”

8. Expansion of deepfake technology for fraudulent

activities
Deepfake technology is being increasingly used for fraudulent
activities, such as impersonating executives to authorise
transactions or manipulating voice recognition systems.
Detecting and preventing these sophisticated attacks require
cutting-edge technology and robust verification processes.

“Deepfake technology is crossing the threshold from novelty to

a significant fraud threat, requiring institutions to rethink their
verification methods”

9. Rise in the exploitation of regulatory sandboxes

Regulatory sandboxes provide a real-world, controlled
environment that enables the testing of technologies over
a limited time and based on a plan agreed with competent
authorities. Regulatory sandboxes, designed to foster
innovation, are increasingly being exploited by criminals to
test fraudulent schemes or launder money. Enhanced oversight
and controls are necessary to prevent misuse while supporting
innovation.

“Sandboxes are a double-edged sword—great for innovation, but

without proper oversight, they become playgrounds for criminals,”
observed a regulatory expert.

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 10. Evolution of insider threat management
Insider threat management is evolving to include advanced
behavioural analytics and monitoring technologies.
These tools help detect and prevent fraud committed by
employees or contractors, who may abuse their access to
sensitive information.

“Behavioral analytics are becoming indispensable for

understanding and mitigating insider threats”

11. Smarter and more targeted sanctions

Sanctions are expected to become more targeted, leveraging
advanced analytics to minimise collateral damage while
enhancing their impact on targeted entities. This requires
better enforcement and coordination across jurisdictions.

“Targeted sanctions are not just about imposing restrictions;

they are about precision and impact, which requires
sophisticated analytics”

12. Expansion of fraud in Peer-to-Peer lending platforms

Peer-to-peer lending platforms, which allow individuals to
lend money directly to others, are seeing an increase in fraud
as criminals exploit their less regulated nature. Enhanced due
diligence and monitoring are needed to protect investors
and borrowers.

“Peer-to-peer lending opens up access to credit but also to fraud.

More stringent controls are necessary to protect users”

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 13. Growth in fraudulent schemes involving elder
financial abuse
Elder financial abuse, where fraudsters target older adults to
exploit their assets or financial information, is expected to grow
due to the increasing digitalisation of financial services and the
vulnerability of elderly populations to social engineering tactics.

“Elder financial abuse is a silent epidemic that’s being exacerbated

by digital channels”

14. Rise in tax evasion and fraud schemes

Tax evasion and related fraud schemes are anticipated to
increase as individuals and organisations attempt to minimise
their tax liabilities illegally. Enhanced collaboration between tax
authorities and financial institutions, coupled with improved
data analytics, will be crucial.

“As tax laws become more complex, so do the schemes to evade

them. Better tools and cooperation are needed to combat this”

15. Expansion of financial crime in emerging markets

Emerging markets are seeing growth in financial crimes as they
integrate into the global financial system, often lacking the same
level of regulatory oversight and infrastructure as developed
markets. Building stronger regulatory frameworks and international
cooperation are crucial.

“Emerging markets present both opportunities and risks—it’s vital

to strengthen oversight to prevent financial crime”

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Radical solutions

As financial crime becomes increasingly complex,

many are pushing for bold, transformative solutions
that could reshape the way financial institutions,
regulators, and governments approach these issues.

These solutions challenge conventional methods and propose sweeping

changes that, if implemented, could change the AML landscape.

Financial crime as a public health issue: Reframing financial crime as a

public health issue could lead to more aggressive interventions.
This perspective would allow governments to allocate resources similarly
to how they handle pandemics, with emergency powers to freeze assets,
force cooperation from private entities, and impose mandatory reporting for
suspicious activities. This could also include public awareness campaigns
similar to those for health crises, aimed at educating the public about the
risks and signs of financial crime​​.

51 AML Megaminds Report First edition V1

 Mandatory integration of AI for all financial institutions: Another radical
idea is to mandate the use of AI and machine learning for all financial
institutions, particularly in transaction monitoring and risk assessment. By
enforcing this across the board, it would ensure that even smaller institutions
with fewer resources have access to advanced technologies capable of
detecting complex money laundering schemes. This would require significant
investment but could dramatically increase the effectiveness of AML
efforts globally​​.

Eliminating traditional banking secrecy: A bold move would be to completely

eliminate traditional banking secrecy laws, making all financial transactions
transparent and accessible to regulatory bodies. This would include not just
sharing information within borders but also cross-border sharing of financial
data, essentially removing any havens for illicit financial flows. The idea is to
make it impossible for criminals to hide behind confidentiality and secrecy​.

Creating public beneficial ownership registries with blockchain verification:

Establishing public, transparent registries of beneficial ownership for all
companies, verified and maintained using blockchain technology, is a radical
approach to combat money laundering. This would make it much harder
for criminals to hide their identities behind shell companies. Blockchain’s
immutability ensures that once the data is recorded, it cannot be altered,
providing a secure and transparent way to track ownership​.

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"Every scam starts with a story that
sounds too good to be true, and it
usually is."
Methodology

The AML Megaminds report is the culmination

of extensive in-depth conversations with experts
from across the AML, compliance, and financial
crime sectors.

The report pulls on podcasts recordings with 84 guests covering 60 hours­—

resulting in 371,000 words when transcribed.

These transcripts were then analysed by an AI platform, our ‘AML Megamind’,

and examined for trends and patterns in topics, sentiment, issues, and events
that are both relevant and engaging.

Topics for the report were carefully selected and considered by our editorial
team.

The report measures the sentiment of responses from guests on a range

of topics. For example, searching terms like “sanctions effectiveness,”
“sanctions working,” “sanctions not working,” and “sanctions mixed views” to
gather relevant expert opinions from the episodes. For each relevant excerpt,
distinct expert views were categorised by three groups of “working”, “not
working” and “mixed views”. Weight was assigned based on the depth and
focus of the discussion, with more significant and focussed commentary
carrying greater influence.

This detailed sentiment analysis strategy was replicated for every topic.

54 AML Megaminds Report First edition V1

A thank you

A report of this scale and depth would not have

been possible without the hard work of The Laundry
production team, who continue to strive to cover the
topics that truly matter to this community.

Nor would it have been possible without the fantastic guests, who
transform a subject often misperceived as a mere tick-box exercise into
one with real-world impact and significance..

Without that passion, the industry would continue to be a black box

of mystery.

55 AML Megaminds Report First edition V1

About Strise

Strise leads the AML automation revolution, transforming compliance teams

into essential assets for organisations. Our commitment to automation,
cutting-edge AI, and user-centred design drives this shift. At the heart of our
innovation is the Strise AML Automation Cloud that powers comprehensive
solutions for Know Your Business (KYB), Ultimate Beneficial Ownership
(UBO) discovery, sanctions and PEP screening, ongoing due diligence, and
automated onboarding of both retail and corporate clients. By seamlessly
integrating data, automation, and compliance workflows, Strise solves
both the data and workflow challenges in AML, delivering unprecedented
efficiency gains for enterprises.

By using Strise, AML and compliance teams are soaring to new heights,
operating at super-speeds and becoming unprecedentedly efficient.
With our approach, users have reported a significant 90% reduction in time
spent on due diligence, from days to minutes, and a 30% reduction in cost.

For more information:

www.strise.ai

56 AML Megaminds Report First edition V1

 Anti-Money Laundering
MEGAMINDS
Adam Vilaça Amalie Korning Wedege Anders Schiøtz Worren Andreas
Prestegaard Engstrand Anette Kristensen Anita Nedergaard Anna Rowe
Åsa Birgersdotter Bruce Viney Bruno Edenogie Carine Smith Ihenacho
Chiara Bacchi Chloe Cina Chris Cook Christian Hunt Christian Wandt
Dame Margaret Hodge, MP Dan McCrum David Silverman Dr. Janet
Bastiman Emil Dall Emma Hagan Erik Blommé Erling Grimstad Fredrik
Riiser Fredrik Söderberg Geoff White Graham Barrow Hege Hagen
Heili Veskimeister Hilde Nordbø Ida Marie Edholm James Nurse James
Young Jan Erik Gran Olsen Jason Mikula Jaypee Soule Jerker Asplund
Jessica Cath John Davidson John Peder Egenæs Jörgen Holmlund
Julie Odden Kajsa Nordborg Kimberly Grauer Kristina Overn Krohn Liron
Shapira Louie Vargas Magnus Johannesen Marcus Mølleskov Maria
Nizzero Marit Rødevand Martin Walker Max Seddon Michael Byrne Miles
Johnson Mitch Trehan Neil Donovan Neira Jones Nicholas Ryder Nicklas
Lundh Olena Loboiko Oliver Bullough Pål Lønseth Patrick Skjennum Pav
Gill Peter Geoghegan Phil Coole Ragnhild Georgsen Robin Lycka Scott
Chipolina Silke Øverby Simon Lock Simon Miller Simon Taylor Susan
Hawley Sven Arild Damslora T. Raja Kumar Tara Abdi Thom Townsend
Tom Cardamone Veronica Glab Viveka Strangert Xavier André Justo