Effectiveness and the Fight Against Financial Crime
At the ACAMS Effectiveness webinar held on 16th July, 2025, this topic was discussed from different perspectives in the fight against financial crime including money laundering. Whilst we have explored much in terms of effectiveness, we still don’t have a clear consistent & common purpose for those involved. We are talking about hundreds of thousands of people & maybe more.
Stakeholder effectiveness has been developed, for example by the Wolfsberg Group for Financial Institutions and by the Global Coalition to Fight Financial Crime for Supervisors. FATF has an overall objective supported by 3 intermediate objectives and 11 effectiveness criteria known as immediate outcomes.
The FATF 11 IO criteria are decent but actual results are underwhelming for most countries which reflects the reality that incredible efforts are not being converted into what matters, with a few exceptions for a few countries in a few IO cases.
FATF Report – Comprehensive Update on Terror Finance Risks – Summary and Dashboard by FCN
The FATF published a 134 page Report on TF risks which follows its previous comprehensive TF update in 2015. FCN have published a 2 page high level summary of this report.
This report will assist both public and private sectors improve their responses, as effectiveness ratings for IO9 (Investigations and prosecutions of TF offences) & IO10 (Prevention of TO activities including TF raising storing moving & using funds including related to NP0s).
Results as at mid 2025 from 197 countries assessed in the last round have just 30% of countries rated positively for IO9 and just 15% for IO10.
The Report covers:
- The main factors influencing Terrorism financing
- The main types of terrorist organisations and or activities
- The main ways terrorist raise, store, move and use funds and key trends over the last decade and the main vulnerabilities and sectors used Trad/Non Trad
- The link between TO, TF and criminal activities and in particular natural resources.
UK Challenger Bank, Monzo fined £21 million by FCA for AML Weaknesses
The Financial Conduct Authority announced fines of £21 million against UK Challenger Bank for serious AML weaknesses between 2018 and 2020. This follows a fine against Starling Bank for £28 million also a UK Challenger bank last year. The FCA found that, key elements of Monzo’s financial crime framework particularly with regard to customer risk assessments and the collection of customer information did not keep pace with the Firms expansion and during the VREQ period. FCA considers that they were inadequate understanding of FC related risks from Monzo’s customers. Prior to the VREQ period, (before 2020), Monzo operated a more limited approach to collecting customer information (CDD) at the point of onboarding. Whilst this facilitated account opening processes, it meant that Monzo did not obtain and or address sufficient information about prospective customers, in particular, the Firm failed to obtain the purpose and nature of the proposed customer relationship, and failed to review all adverse media alerts for a customer unless other risk factors were present.
FATF R16 From the Travel Rule to Payment Transparency – Recent Changes – Assessment by FCN
The FATF published updated payment transparency standards following their approval in June 2025, after a few years of consultation. The hard work to reach agreement has to be recognised and in particular the work of FATF’s Policy Development Group led by Co Chairs Takahide Habuchi & Elad Weider This initiative may well have been one of the toughest tasks FATF has undertaken and 2 consultations reflect the challenges involved, but also the wider environment. After many years a FATF compromise and agreement has been reached and agreed by policy makers. Whether it gets supported through to full implementation is still a concern, especially as the new standards have an implementation period that runs to 2030 and can still be extended and 4 FATF important member countries have long been only partially compliant with the old standards including the USA & Australia.
FATF Report on Complex Proliferation Finance & Sanctions Evasion Schemes – Summary and Dashboard by FCN
The Financial Action Task Force (FATF) have just released a new report on Complex Proliferation Finance and Sanctions Evasion Schemes. Clearly topical and despite FATF’s mandate limited to UN sanctions this is by extension a back door way of also applying FATF expectations on UN approved sanctions compliance to other sanctions compliance expectations. Compliance with FATF Recommendation 7 and Immediate Outcome 11, from 194 countries needs significant improvement so findings from this report will help.
North Korea (DPRK) and Iran are the main targets, but Russia also comes in to the report, due to its ties in particular with DPRK. As all are currently persona non gratis at FATF, there is an opportunity to push the envelope a bit here and readers will consider some of the contents also applying in practice to other non UN approved sanctions.
Latvia Financial Crime Summary & Dashboard by FCN – 2025
1. Introduction
Today Financial Crime News is publishing a Financial Crime Dashboard (see Annex 1) for Latvia and a summary of the progress made, a week after the new Moneyval report for Latvia was discussed at the joint FATF Moneyval Meeting and is said to be positive. Nevertheless, we will have to wait until Q4 2025 as Latvia is the first country to be assessed under the 6th round of country evaluations so it will go through a full quality check. For the avoidance of any doubt, FCN has not seen a copy of the report and is not aware of any of its findings and this paper has been compiled from publicly available information curated by the FCN Editor.
Latvia’s reputation then was as a major ML centre, at the centre of laundering tens of US$ billions in illicit financial flows from the former CIS including Russia into the EU/Eurozone and beyond, with ML scandals, Bank closures, and even the Central Bank Governor arrested for bribery (later found guilty and sentenced to 6 years imprisonment).
Financial Crime Dashboard for Singapore by FCN
Today Financial Crime News is publishing an updated Financial Crime Dashboard on Singapore after spending a few weeks meeting many financial crime leaders in the city state, and just ahead of the FATF assessors coming to town for their 5th round onsite. See: FCN Singapore Dashboard June25Pbd
The last full FATF evaluation was published in 2016 with a follow up report in 2019 so a lot has changed since then, both in terms of the threat and the response. See for 2016 & See for 2019:
The last FATF report and ratings provided Singapore with a can do better report card and whilst technical compliance was pretty good as expected it was in the areas of effectiveness where improvements were required, with just 4/11 Immediate outcomes rated positively.
UAE National ML/TF Risk Assessment 2024
The UAE ML/TF Risk Assessment 2024 dropped last week and it’s a very big improvement on those prior NRA extracts reported in 2019 and 2021. The UAE has been through a lot during this period, including being added and then removed from FATF’s Grey List. FCN has reported on the journey the UAE has been on including reporting on improvements made, which suggest where genuine political commitment to make improvements in combatting financial crime and money laundering are real a lot can be achieved. No country is immune or has a spotless record on fighting financial crime and money laundering but those that need to do most are those that in particular have major international trading and financial relationships where illicit goods and transactions have always flowed, and seek to hide amongst the legitimate activity.
Are Online Scams really on a par with Illegal Drugs as claimed by the Economist? – Not yet
Scams made the front cover of the Economist’s Feb 8, 2025 edition titled “Scam Inc”. It claims, “every year US$500bn is stolen in online scams” and now it “rivals the international drugs trade”. The source is an “expert in Chinese organised crime who was a police officer in Hong Kong for 11 years. That puts scamming on a par with the illegal drugs trade as one of the world’s biggest illicit industries”. The source named in the piece is well credentialed but he left the HK Police in 1999. Is the Economists claim that online scams or on a par with drug trafficking really valid? Probably not, or at least not yet, according to available sources.
According to the UNODC cyber enabled fraud proceeds from SE Asian victims & or from SE Asia based criminals generated between US$18 – US$37bn.
Bank & FI AML/Sanctions Fines & Penalties in the 21st Century
AML and Sanctions related Major fines (exceeding US$10 million) reached US$45.679 billion for the 21st Century (2000 – end 2024). 85 AML related fines generated US$27.886 billion and 26 sanctions related cases generated US$17.793 billion.
2024 was a bumper year for the value of AML fines (US$3.3 Billion from 8 cases) whereas 2023 saw only one major fine (US$186 million).
AML related fines are also on the increase as more countries come under pressure to impose fines and for fines to be ever larger. Sanctions enforcement is up outside of the US, with the EU, UK and Switterland becoming more active.
- AML Related Fines
Whilst the results provide a total aggregate amount of US$28 billion, put into context it is likely similar to the amounts seized from financial criminals and money launderers annually.
