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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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Compliance Without Conscience: Why Algorithms Cannot Replace Ethical Judgement
When the Financial Action Task Force (FATF) published its updated Guidance on the Risk-Based Approach in 2023, it acknowledged for the first time the growing role of artificial intelligence (AI) and machine learning in anti-money laundering and counter-terrorist financing (AML/CTF) frameworks. The language was cautiously optimistic: these technologies, the FATF suggested, could strengthen the identification of suspicious activity, reduce false positives and allow compliance t

Elizabeth Travis
4 days ago7 min read


AML Fatigue: Has Compliance Lost Sight of Criminal Purpose?
When the Financial Action Task Force (FATF) published its original forty Recommendations in 1990, the objective was unambiguous: to deny criminals the ability to launder the proceeds of drug trafficking through the international financial system. Over the three decades that followed, this mandate expanded to encompass terrorist financing, proliferation finance, corruption, tax evasion and a widening catalogue of predicate offences. Successive rounds of mutual evaluations, new

Elizabeth Travis
Apr 136 min read


DOJ Targets Black-Market Peso Exchange Network in Texas Cartel Money Laundering Case
The US Department of Justice (DOJ) has secured a guilty plea from a Mexican national tied to a multimillion-dollar black-market peso exchange scheme, marking another significant enforcement action against cartel financing networks. Announced on 8 April 2026, the case centres on Gabriel Arturo Castillo, 52, of Monterrey, Nuevo León, who admitted his role in a two-year trade-based money laundering conspiracy designed to move drug proceeds from the US to Mexico without physicall

OpusDatum
Apr 83 min read


FinCEN Moves to Overhaul AML Rules
FinCEN has proposed a sweeping rewrite of anti-money laundering and countering the financing of terrorism programme requirements that could materially reshape how financial institutions design, evidence and defend their compliance frameworks. Announced on 7 April 2026, the proposal is positioned as a fundamental reform of Bank Secrecy Act AML/CFT expectations, with Treasury arguing that firms should be judged less on process-heavy documentation and more on whether their contr

OpusDatum
Apr 74 min read


Who Pays for Compliance? The Unintended Consequences of Extraterritorial AML Law
In June 2000, the Financial Action Task Force (FATF) published its first list of Non-Cooperative Countries or Territories, identifying fifteen jurisdictions deemed deficient in their anti-money laundering (AML) controls. The initiative was presented as a necessary corrective: a mechanism for bringing the global financial system into alignment with a common set of standards. Twenty-six years on, the FATF’s mutual evaluation process has matured into one of the most powerful ins

Elizabeth Travis
Mar 308 min read


FinCEN Targets Health Care Fraud and Expands Whistleblower Incentives
FinCEN has sharpened its focus on health care fraud with a new Advisory warning financial institutions about increasingly sophisticated schemes targeting Medicare, Medicaid and other government health care benefit programmes. Released on 30 March 2026, the Treasury measure frames health care fraud not simply as a billing abuse issue, but as a money laundering and national security concern involving organised crime groups and transnational criminal organisations. The Advisory

OpusDatum
Mar 303 min read


FCA Fines Dinosaur Merchant Bank for CFD Surveillance Failings
The Financial Conduct Authority (FCA) has fined Dinosaur Merchant Bank Limited (DMBL) £338,000 for significant failures in its market abuse surveillance systems within its contracts for difference (CFD) business. The enforcement action underscores regulatory expectations that firms operating in high risk trading environments must maintain robust and effective monitoring frameworks. The failings arose following the introduction of a new order management system in June 2024, wh

OpusDatum
Mar 272 min read


FCA Bans Kasim Garipoglu Over Dishonesty and AML Failings
The Financial Conduct Authority (FCA) has banned Kasim Garipoglu from working in UK financial services after concluding that he is not fit and proper because of a sustained lack of honesty and integrity. The decision marks another high-profile enforcement action as the regulator continues to prioritise financial crime, senior manager accountability and market integrity. According to the FCA, Garipoglu, who owned a firm offering online foreign exchange and contracts trading, r

OpusDatum
Mar 133 min read


Low Risk by Decree: Why the Epstein Files Shatter the UK’s PEP Presumption
In January 2024, the UK amended its Money Laundering Regulations to introduce a statutory presumption that domestic politically exposed persons (PEPs) present a lower level of risk than their foreign counterparts. The Financial Conduct Authority (FCA) cemented this position in July 2025 with Finalised Guidance FG 25/3, instructing firms to apply less intrusive measures to UK PEPs unless other risk factors intervene. The message was clear: domestic political exposure, in the U

Elizabeth Travis
Mar 96 min read


FinCEN Hits Canaccord With Record $80m AML Penalty
The Financial Crimes Enforcement Network (FinCEN) has imposed an $80m civil money penalty on broker-dealer Canaccord Genuity LLC for willful violations of the Bank Secrecy Act (BSA), marking the largest enforcement action ever taken against a broker-dealer under the anti-money laundering (AML) framework. According to the U.S Department of the Treasury, Canaccord failed to implement and maintain an effective AML programme, conduct appropriate customer due diligence (CDD), and

OpusDatum
Mar 62 min read


OPBAS Calls For Stronger Enforcement By AML Supervisors
The Office for Professional Body Anti-Money Laundering Supervision (OPBAS) has warned that anti-money laundering supervision across professional services still lacks sufficiently strong enforcement to deter poor compliance. In its latest report, OPBAS found that Professional Body Supervisors (PBSs) overseeing legal and accountancy firms are more effective than at any point since the body was established in 2018. However, the regulator concluded that several supervisors contin

OpusDatum
Mar 32 min read


Japanese Trafficker Jailed for Nuclear Materials & Money Laundering Plot
Takeshi Ebisawa, a Japanese national, has been sentenced to 20 years in prison in the United States for his role in an international criminal conspiracy involving nuclear materials trafficking, narcotics distribution, firearms dealing and money laundering. The sentencing was handed down by US District Judge Colleen McMahon in the Southern District of New York after Ebisawa pleaded guilty to six charges related to the scheme. The case centred on an extensive criminal network s

OpusDatum
Mar 32 min read
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