The assessment cases

FinCEN's 2024 alert on deepfake media in identity documents, the National Crime Agency's 2025 assessment of generative AI in fraud, and FATF guidance on beneficial ownership obfuscation.

Mule-network consolidation patterns described in NCA SARs in Action bulletins, romance and investment fraud proceeds typologies, and FinCEN's 2025–26 actions concerning nested payment infrastructure.

FATF trade-based money laundering typologies, including recent updates covering supply-chain and receivables finance structures.

National Crime Agency SAR quality guidance and glossary code expectations.

Wirecard's third-party acquiring balances; EBA Report on virtual IBANs (May 2024); FCA payments portfolio letter (3 February 2025) on agent and distributor oversight; the 2025 UK National Risk Assessment raising EMIs and payment firms to high risk.

FATF guidance on virtual assets and offshore VASPs; OFAC designations of Blender.io and Tornado Cash; Elliptic's State of Cross-Chain Crime 2025; FATF Targeted Report on Stablecoins and Unhosted Wallets (3 March 2026); FinCEN Alert FIN-2024-Alert004.

FinCEN Alert FIN-2024-Alert004 (13 November 2024) on generative AI used to circumvent identity verification; Group-IB's Weaponized AI (January 2026) on biometric injection attacks; the Arup Hong Kong transfers of January 2024, executed after a video call on which every other participant was an AI impersonation; and Federal Reserve material on synthetic identity fraud.

Deutsche Bank mirror trading — the FCA's £163m Final Notice of 30 January 2017 and the New York State Department of Financial Services' US$425m consent order; FATF and Wolfsberg material on the misuse of securities markets and private placements; and OFSI and OFAC guidance on ownership and control below designation thresholds.

SRA Accounts Rules rule 3.3, prohibiting use of a client account to provide banking facilities; SRA warning notices on source of funds and source of wealth in property work; Council for Licensed Conveyancers guidance on mortgage fraud; FATF on real estate and professional intermediaries; and Companies House dissolution records.

FATF on money laundering from environmental crime (July 2021) and on the vulnerabilities of free trade zones (March 2010); the G7 price cap on Russian crude and OFAC designations of vessels operating outside it; Wolfsberg's Principles for Correspondent Banking (2022); and OECD due diligence guidance for mineral supply chains.

FATF and the Egmont Group, Financial Flows from Human Trafficking (July 2018); NCA and UKFIU modern slavery indicators for the regulated sector; AUSTRAC's Detect and Report Cuckoo Smurfing (June 2021) and Lordianto v Commissioner of the Australian Federal Police [2019] HCA 39; and Gangmasters and Labour Abuse Authority licensing standards.

FATF's Comprehensive Update on Terrorist Financing Risks (July 2025) on the shift toward sham non-profits, and Recommendation 8 as amended at the October 2023 Plenary; RUSI's Reassessing the Financing of Terrorism (2025); Charity Commission guidance on trustee records; and chain-analytics reporting on extremist fundraising, labelled indicative.

FinCEN Notice FIN-2021-NTC3 (16 September 2021) and its financial trend analysis on online child sexual exploitation, which supply the indicator set; NCA and UKFIU guidance on reporting and the use of key terms; and FCA guidance on the fair treatment of vulnerable customers.

The National Risk Assessment 2025 (July 2025), which assesses the money laundering risk for accountancy service providers as high and names accountants' certificates of confirmation as a route by which falsified accounts are given effect, and its paragraph on phoenixing; Elphysic Ltd & Ors v HMRC [2025] UKUT 236 (TCC) on mini-umbrella structures and nominal directors; FATF, Professional Money Laundering (July 2018); and FATF Recommendation 8 as amended in October 2023, which is why de-risking the charity scores as an error.

European Commission v Malta (CJEU, Case C-181/23, judgment of 29 April 2025) on citizenship-by-investment as commercialisation of member state nationality, with the joint FATF and OECD report on misuse of citizenship and residency by investment programmes; the National Risk Assessment 2025 on the art market and on estate agency and lettings; the 2019 amendments to the Money Laundering Regulations, which brought art market participants and letting agents into the regulated sector; and SRA Accounts Rules rule 3.3, which is why a distribution from a regulated firm's client account carries weight a private company's payment does not.

The National Risk Assessment 2025 (July 2025), paragraphs 6.15 to 6.21, on clubs used as a vehicle to launder funds and as a destination for criminal investment through sponsorship and image rights, and on player values being difficult to determine objectively; FATF, Money Laundering through the Football Sector (July 2009), drawing on 25 countries and over 20 case examples; and Operation Lava Jato, in which Odebrecht and Braskem admitted approximately US$788m in bribes and paid US$3.5bn to resolve charges, as the reference case for improper payments routed as consultancy fees.

NCA Operation Destabilise (December 2024), which exposed a network collecting criminal cash across 28 UK cities, leading to 128 arrests worldwide and over £25m seized; Cifas Fraudscape, recording more than 22,000 money-muling incidents in 2025, a 43 per cent rise on the prior year; the Europol-coordinated parallel-banking action of January 2025, in which hawala settlement, cash collection and crypto exchange ran as one service; FATF and MENAFATF on the physical transportation of cash (2015) and Recommendation 32; and the Gambling Commission's 2026 risk assessment, which rates betting at the highest risk band.

The US and UK joint action of 15 October 2025 against the Prince Group, in which OFAC designated 146 individuals and entities and the UK froze 19 London properties worth over £100m; FinCEN's finding that Huione Group is a foreign financial institution of primary money laundering concern (1 May 2025), alleging at least US$4bn laundered; FATF's Targeted Report on Stablecoins and Unhosted Wallets (3 March 2026), attributing 84 per cent of illicit virtual asset volume in 2025 to stablecoins; R v Osunkoya, the FCA's first prosecution for unregistered cryptoasset activity, four years' imprisonment; and OFAC's advisory on facilitating ransomware payments.

Axel Kittel v Belgian State (CJEU, C-439/04, 2006), under which input tax is denied where a trader knew or should have known its transactions were connected to VAT fraud, ignoring suspicious pricing or opaque supply chains being sufficient; EPPO Investigation Nebula (27 May 2026), seven arrests over an estimated €78m of unpaid VAT through missing-trader companies registered to strawmen; HMRC enforcement against inward diversion of alcohol, with roughly 8 per cent of £12.6bn in duty uncollected annually; FinCEN's advisory on Chinese Money Laundering Networks (28 August 2025) on mirror transactions and daigou settlement; and EUIPO and OECD, Mapping Global Trade in Fakes 2025.

The Svenska Dagbladet investigation (2023), in which gang members described buying fraudulent streams of music by connected artists; Chainalysis on NFT wash trading (2022), identifying 262 users who each sold to a self-financed address more than 25 times; FATF's risk-based guidance for the life insurance sector (October 2018), recording that insurer payments are widely assumed clean; Insolvency Service enforcement disqualifying 1,036 directors in 2024-25, 736 for Covid loan abuse; and OFAC's action of 12 March 2026 on DPRK IT worker fraud generating close to US$800m in 2024.

FATF's Guidance for a Risk-Based Approach for the Life Insurance Sector (October 2018), which identifies early surrender at a penalty, third-party premium and changes of beneficiary as the principal indicators and records that insurer payments attract little downstream scrutiny; OFSI and OFAC guidance on ownership and control where a holding is restructured below a designation threshold; Bribery Act 2010 and SFO enforcement on commission paid to a party with no capacity to perform the service; and the Arup deepfake case of January 2024 alongside FinCEN Alert FIN-2024-Alert004 on AI used against authentication controls.

Gambling Commission Licence Conditions and Codes of Practice on source of funds and third-party payments; Gambling Commission enforcement including the £19.2m regulatory settlement with William Hill Group (March 2023), the largest in its history, £17m against Entain (November 2022) and £9.4m against 888 UK (August 2022), each turning on customers permitted to stake substantial sums with no meaningful source of funds enquiry; FATF's Vulnerabilities of Casinos and Gaming Sector (March 2009); and FinCEN Alert FIN-2024-Alert004 (13 November 2024) on liveness checks defeated by injection.

Companies House identity verification, mandatory from 18 November 2025 under the Economic Crime and Corporate Transparency Act 2023, introduced against nominee-fronted structures; the NCA operation of 16 July 2025 striking off 11,500 companies, one address having registered between 4,000 and 5,000 businesses; FATF Recommendations 24 and 25 with the guidance on beneficial ownership of legal persons (March 2023) and legal arrangements (March 2024), under which a protector holding powers to remove a trustee must be identified; OFSI guidance on ownership and control where a holding is restructured below a designation threshold; and the fact that UK death registration does not capture deaths abroad, so a controlling person who dies outside the jurisdiction stays alive to a firm's screening indefinitely.