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Our latest thinking on financial crime compliance, regulatory change, technology, and the forces reshaping global risk management.
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The Price of Deception: What Cheap Fraud Does to Expensive Controls
On 6 July 2026 the Financial Conduct Authority (FCA) published the Mills Review, its assessment of how artificial intelligence will reshape retail financial services by 2030. The commentary that followed went looking for a new crime. The techniques the Review names, deepfakes, synthetic identities and personalised social engineering, are not new offences; they are the methods financial crime teams have countered for years, and what the Review says has changed is that attacks

Elizabeth Travis
5 days ago7 min read


One Bank Said No: The Refusal That Stopped Nothing
In December 2018 a company applied for a bank account in Douglas. Amiga Entertainment, incorporated on the Isle of Man two months earlier, wanted to bank with Cayman National Bank. The bank asked where the money behind it came from and was told that its ultimate owner had started out with a $2 million loan from an uncle. In October 2019 a compliance officer asked for the uncle's name and the origin of his funds; nobody replied, and the application failed. Judged as an onboard

Elizabeth Travis
Sep 287 min read


Alerts Are Not Evidence: AMLA Redraws the Monitoring Obligation
On 3 June 2026 the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) opened a consultation on how firms should watch a customer relationship once it has begun. It reads, at first, like housekeeping: guidance issued under Article 26(5) of the Anti-Money Laundering Regulation (AMLR), horizontal in scope, technologically neutral, insistently proportionate. More than 1,200 people joined the public hearing on 2 July, which is not the audience an

Elizabeth Travis
Sep 217 min read


From Operator to Observer: Where AI Accountability Goes to Hide
The Senior Managers Regime (SMR) has spent the best part of a decade making accountability personal. Named individuals. Defined responsibilities. Reasonable steps. People, not just firms, answerable when things go wrong. Yet the Mills Review, published by the Financial Conduct Authority (FCA) in July 2026, raises a quietly unsettling question about that achievement: as firms hand more of the work to artificial intelligence, and the human role drifts from doing to overseeing,

Elizabeth Travis
Sep 146 min read


Transparency for Borrowers: The Register the United States Chose to Delete
The International Monetary Fund (IMF) completed a guidance note on 25 June 2026, released the following month, instructing its staff on how to build financial crime into surveillance, financial sector assessments and lending decisions. Seven weeks later, on 11 August, the Financial Crimes Enforcement Network (FinCEN) published a final rule removing the obligation on US companies to report who owns them. Most of what had already been reported will be erased. The two documents

Elizabeth Travis
Sep 78 min read


Sanctioned Until Convenient: What a 135-Day Designation Tells Compliance
On 12 December 2025 a sitting justice of Brazil's Supreme Federal Court came off the Specially Designated Nationals list in a routine data release, with no press notice of the kind that had announced his designation. On 30 July 2025 the Office of Foreign Assets Control (OFAC) had designated Alexandre de Moraes under the Global Magnitsky programme, twelve days after the State Department revoked his US visa. Treasury Secretary Scott Bessent said he had run a campaign of censors

Elizabeth Travis
Aug 317 min read


The Payment Messages Your Filter Never Reads
Count What Reached The Filter Most screening management information can tell you how many alerts were raised last month. That number describes what the filter did with the messages it received. It is the far end of the process. Ask a different set of questions about what happens at the beginning and things can get a little less clear. How many payment messages did the bank process that month? How many were in-scope for payment screening (probably not screening domestic but I

Andrew Travis
Aug 264 min read


Measuring the Mirror: What FinCEN's Human Smuggling Filings Actually Record
On 13 August 2026 the Financial Crimes Enforcement Network (FinCEN) published a Financial Trend Analysis on human smuggling. It examines 67,540 Bank Secrecy Act (BSA) reports filed between 2023 and 2025, carrying more than $4.9 billion in suspicious activity, and its headline finding is a collapse. Filings peaked at 29,266 in 2024 before falling to 11,018 in 2025, a decline of 62 per cent, which the report sets beside US Customs and Border Protection figures showing crossings

Elizabeth Travis
Aug 248 min read


The Unguarded Verdict: The EU AI Act's Financial Crime Blind Spot
New rules that took effect in the United Kingdom on 28 April 2026 require banks to give a customer at least 90 days' notice before closing their account, and to set out the reasons in writing. Yet the reform, meant to answer years of anger over debanking, carries an exception that reaches to the heart of the matter: a provider need give neither notice nor explanation where it has reasonable grounds to suspect the account is connected to serious crime. That judgement, whether

Elizabeth Travis
Aug 177 min read


The Teeth Behind the Standard: What AMLA Now Means for Cross-Border Firms
For two decades, the European Union wrote anti-money laundering rules and then watched twenty-seven member states enforce them twenty-seven different ways. Danske Bank, Wirecard and ABLV were not aberrations. They were the predictable output of a system in which supervision was national, ambition was European, and the gap between the two was where laundered money moved. The Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) was built to close

Elizabeth Travis
Aug 107 min read


When Compliance Becomes Theatre: The Risk of Symbolic Regulation
In April 2026, a panel convened by the Huggard Consulting Group in Washington reached a damning verdict on the global fight against money laundering. This was no gathering of fringe critics. It included two former directors of the United States Financial Crimes Enforcement Network (FinCEN), among them William Fox, alongside the President of the Bank Policy Institute and a former chief of the Justice Department's money laundering section. The panel concluded the system had bec

Elizabeth Travis
Aug 36 min read


The Account That Was Never Real: How Synthetic Identities Defeat Modern KYC
When a bank approves a new customer, it assumes one thing above all else: that a real person sits behind the application. For most of the history of customer due diligence, that assumption held. The fraudster of the past stole an identity that belonged to someone, and somewhere a victim would eventually notice. Yet synthetic identity fraud breaks that logic entirely. There is no victim to raise the alarm, because the person being onboarded does not exist. The identity is asse

Elizabeth Travis
Jul 276 min read
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