In ACFCS’ Future of Fincrime Skills 2025 virtual summit, compliance professionals, investigators sharpening use of AI, homegrown, regional partnerships to slay rampaging scam leviathan – giving hope to victims, victors

By Brian Monroe
March 28, 2025
bmonroe@acfcs.org

What does the future of financial crime look like? Who are the Spartans willing to battle a relentless enemy and what skills and weapons should they be sharpening in this high-stakes battle?

Is there even a skillset that a professional can craft to defeat all the ways a criminal can launder money? Is there a technological toolkit that can reveal and repeal all the ways a scammer can defraud a bank, a company – an individual?

For decades it seems the answer for so many of these questions was a resounding, deflating and deafening no.

But after ACFCS’s Future of Fincrime Skills 2025 virtual summit that took place between March 12-13, panelists and attendees dared to challenge history, fate and look at the future with something other than fear.

They dared to dream of winning – with the spark of hope kindling anew in their eyes, the fire of courage burning bright in their hearts.

From snapshots of crafty, creative and courageous compliance champions using artificial intelligence (AI) to create algorithms on the fly to fight human trafficking – and using these generative and intuitive engines to amplify and streamline prior programs – to government and private sector groups taking a whole-of-country approach to nearly half fraud figures, this year’s event had a different feel.

This year the event highlighted that efforts to investigate and prosecute far flung fraud groups and arm customers are making a tangible difference – with recent U.S. and foreign media reports noting arrests of seemingly untouchable kingpins and raids of Southeast Asian scam compounds.

As for the answer of what does the fincrime fighter of today look like?

These professionals are respected compliance leaders, easily shifting from classic investigative foundations based on expertise and experience – ever-invaluable instinct – to bleeding-edge, AI-empowered generators of innovation crafting and communicating so perfectly with technology they might as well be cyborgs.

These fincrime champions aggressively seek to team with other departments, banks and law enforcement groups at all levels anywhere in the world.

Why?

That way, this compliance coalition of the willing can more quickly uncover, report and react to the illicit creativity and ample agility of threat actor groups to hop between corporeal and digital worlds, industries and payment methods.

Oh, and fearing the regulator?

That mindset is a thing of the past. The compliance officer of our time looks forward to examiner interactions – eager and excited to share tails of trial, tribulation – but ultimately triumph.

Those are just some of the takeaways of ACFCS’ Future of Fincrime Skills event, a member-exclusive virtual summit which saw nearly 1,000 current and former compliance officers, regulators, investigators and technology thought leaders come together to tackle the biggest challenges in the compliance space.

By the Numbers: Future of Fincrime Skills 2025 Attendance Snaphsot

Here is a breakdown of where attendees hailed:

Nearly 1,000 speakers and attendees from 74 countries.

• U.S - 59 percent
• Canada - 12 percent 
• India - 4.4 percent
• UAE - 2.2 percent
• Nigeria – 2 percent
• Caymen Islands - 1.5 percent
• United Kingdom - 10 1.1 percent

The event also saw record attendance in several sessions, including tips to better capture open-source intelligence, tackle terror finance, craft suspicious activity reports (SARs) and look at strengthening AML programs and strengthening fraud countermeasures through the lens of federal regulators. 

Comments from attendees noted that they appreciated opportunities to understand law enforcement, their “organizations and what they are looking for as well as opportunities to engage with their offices for better collaboration,” said one speaker.

“The topics are things that we can relate to, as we are seeing these things within our reviews,” said another attendee.  

“I wasn’t expecting for the lecturers to be so detailed and precise,” said a bank compliance professional.

Another attendee noted that the topics were relevant and timely.

“I'm always amazed at how your topics so closely align with our needs,” said the person.

And lastly, a positive sentiment for ACFCS events current and prior.

“I love the ACFCS events,” said the attendee. “They are wonderful and have some of the best and most informative speakers and topics.”

Organized criminal groups less innovators, more early adopters, illicit adapters

While the attendees of the event hailed from parts far and wide, they all had the same goal: try to more effectively look at their world as a wily, crafty criminal would.

Illicit operators are always looking for the path of least resistance to take advantage of a new gap in oversight or vulnerability in a fresh product.

But are they really doing anything new and coming up with new strategies to launder money?

Not so, according to John Tobon, an adjunct professor at Florida International University and former Assistant Director of the Countering Transnational Organized Crime Unit for thecDepartment of Homeland Security, during his opening keynote session for ACFCS’ Future of Fincrime Skills 2025.

“The notion that criminal organizations create and innovate [when it comes to financial crime] is wrong,” he said. 

“They adapt. They spend zero dollars on research and development. They use what they have seen already works. They use their knowledge of the system and understanding of the system to put their money through. I look at the [financial services] industry to innovate and I look at the criminals to exploit.”

 

In Canada’s fight against fentanyl trafficking, ‘Project Guardian’ creates a template for public, private sector cooperation, global investigations 

One area of desperately needed innovation is in finding and fighting the epidemic of synthetic opioids – chief among them fentanyl.

“The organized criminal production and trafficking of synthetic opioids generates revenues worth tens of billions of dollars annually, while overdoses kill tens of thousands each year,” with an estimated 80,000 people dying just to fentanyl overdoses alone.

Uncovering the laundering networks is also not easy, according to reports and figures published by the U.S. Drug Enforcement Agency (DEA) and Financial Action Task Force (FATF).

“Synthetic opioids supply chains are diverse, and so are the methods used to launder the proceeds,” according to a November 2022 FATF report. “There does not appear to be a single, global ‘business model.’ Rather, the methods vary on a country-by-country and drug-by-drug basis.”

Further complicating crushing these networks is a change to trafficking in pre-cursor chemicals – rather than finalized drugs.

“Whereas fentanyl was procured in the past directly from chemical producers, the class-wide scheduling of most fentanyl-related substances means that today, criminals use precursor chemicals to manufacture drugs such as fentanyl,” according to FATF.

“This relatively recent trend can make it difficult to detect suspicious financial activity.”

That was a trend also noticed by Canada’s Financial Intelligence Unit (FIU), Fintrac, that took aim at the problem of fentanyl trafficking and soaring overdose deaths in 2017 with what would later become “Project Guardian.”

At that time, Fintrac began scouring its database for suspicious transactions involving fentanyl and quickly and broadly sharing those with relevant law enforcement partners, according to speakers during a Future of Fincrime skills panel on the subject and a primer sheet about the initiative.

In February 2018, Fintrac launched Project Guardian as a new public-private sector initiative to combat the trafficking of illicit fentanyl, building off of the successes of prior partnerships, “Project Protect” and “Project Chameleon.”

Project Protect, launched in 2016, focused on combating human trafficking for sexual exploitation by targeting money laundering, while Project Chameleon, launched in 2017, shifted the focus to the surge in romance fraud.

Both projects had Fintrac, banks and law enforcement working together to share and analyze data to better identify the tactics, tricks and transactions by trafficking groups and scammers.

The goals were to uncover both broad and specific trends to better protect victims, prevent devastating financial losses and more effectively arm bank fraud and anti-money laundering teams to identify and report on such crimes.

Projects Protect, Chameleon and Guardian “demonstrate the leadership of Canada’s financial institutions who not only want to comply with their obligations but are also willing to find innovative ways to help in the fight against money laundering and terrorist activity financing,” according to the Project Guardian primer.

 

Why did Canada go from fentanyl ‘user’ to ‘producer’ and eventually ‘distributor?’

Several trends converged to move Canada from a “user” of fentanyl, to a “producer” and even “distributor” of fentanyl, according to panelists and government reports.

One overriding catalyst was the coronavirus pandemic.

It put more people at home, increasing overall drug use. That roughly coincided with China cracking down on finalized pills and criminal groups small and large moving to focusing more on moving and collecting pre-cursor chemicals.

For drug gangs, it is significantly easier to ship and move precursor chemicals from China or India than grow a crop from a given plant, refine and the product and then cut and distribute the product to low-level sellers – all the while with global investigators and drug sniffing dogs nipping at their proverbial heels.

Why the pivot to synthetic drugs?

Users get a high similar to heroin and dealers can get product, but without the need for land, growing and shipping the drugs as the labs for fentanyl and other synthetic opioids only need basic equipment you can store in a garage created from cheap chemicals from China and India.

You don’t even need legitimate trained chemists as the production information can be found in forums online.

The end result for criminal groups: Reduced labor and logistics costs and a shorter, tighter supply chain.

“With synthetic drugs, you can bring the supply to the demand,” said one speaker on the panel. “Can do it in a garage, under the roof of a condo building.”

But how much does it really cost to start a fentanyl lab and what is the profit potential?

It two words: nothing and staggering.

A criminal can get all the chemicals needed to start production with $800, producing $415,000 a kilogram of fentanyl powder, roughly $3 on the street, equating to 200 times to 800 times the cost of the precursors.

Currently, Mexico-based transnational criminal organizations (TCOs), such as the Sinaloa cartel and the Jalisco New Generation cartel (CJNG), have become the predominant traffickers of fentanyl and other synthetic opioids into the United States.

Even so, with so much product being created locally and money moving internationally, that opens the door for investigators to uncover the production and distribution nodes.

For example in one interdiction, Canadia authorities took down a synthetic opioid “superlab” that produced fentanyl for all of the country’s domestic consumption, snaring some 40 million doses.

New AML exercise: re-ranking customer risk through lens of synthetic opioid channels

That begs the question: What kinds of companies should or could be considered more high risk to be involving in the production or distribution of synthetic opioids?

Some sectors banks and law enforcement could consider as being part of the fentanyl trade include, foreign chemical brokers, freight forwarding companies organizing the customs paperwork – land, border and air cargo, domestic storage facilities, operations using U-Haul frequently.

On the distribution side, look for email money transfers and individuals receiving payment for the sale of fentanyl at the street level and related deposits that look like structured cash deposits.

Fintrac found connections to businesses purchasing pill presses, industrial ventilation equipment, vitamin and supplement sellers, protein powder and vitamin C, research and development companies, anabolic steroids.

Then overlay that information with hefty purchases of pharmaceutical packaging, heavy machinery or supplies for production lines.

One of the most obvious and powerful indicators of current illicit activity is they were named or convicted of prior illegal acts or have links to blacklisted individuals, companies or regions.

One of the ways Fintrac found leads to investigate opioid trafficking in its own country was looking at entities sanctioned by the U.S. Treasury’s Office of Foreign Assets Control (OFAC) supplying precursor and finished products to the United States.

“We asked the question: is there a Canadian nexus?” said one speaker.  

The answer was yes.

In one instance, the owner of a natural health product company in Canada was previously arrested for production of fentanyl and alprazolam.

In another connection, a vitamin and supplement company in Canada was previously found to be selling fentanyl and meth precursors from China, meth and MDMA.

Lastly, Canadian authorities uncovered that a single family home builder in Canada had connections to an Indian-based company that was recently indicted by the U.S. for importing fentanyl precursors chemicals,

In this surge of use and overdoses, Fintrac reviewed thousands of suspicious transaction reports (STRs) filed by the financial sector to identify the proceeds of fentanyl trafficking and the related financial profiles of a user, producer and distributor.

The results produced from those analyses came in the form of new indicators Fintrac released in December.

However, speakers during the panel noted that there is no one indicator that can uncover illicit operations.

Bank investigators must look at both “transactional and contextual indicators,” such as a supplement company moving more money than usual also importing a chemical typically not needed or used for their business or even allowed for human consumption.

“It’s not just a single transaction, but how have they changed over time.”

When it comes to reviewing the risks of customers that could have gone rogue for fentanyl riches, look at the big picture and the contextual changes over time – including not just their direct connections to illicit activity, but links to customers and broader networks.

“Who else is surrounding the individual and entity and what are the relationships you find when you move up or down the tree,” one speaker said.  

At times, compliance teams may even have to reach out to businesses, asking them if they have the appropriate import licenses – and the responses themselves may add dimension to the risk of criminal activity.

“Gauge the responsiveness of your client,” said one panelist. “Are they not responding? Are they cagey or hesitant? They should know what they do. Are they engaging in transactions they have never done before – such as millions of dollars in business to China?” 

 

Synthetic Opioid Snapshots: Why does a local supplement company spend so much on chemicals not fit for human consumption coming from China?

What does production and distribution of synthetic opioids look like through the lens of AML transaction monitoring systems for certain customers and businesses related to overall domestic and international spending patterns?

Let’s take a look:

Indicators of synthetic opioid production

Why rent where you live? Why buy chemicals with no ties to your business?

·                Client makes payment for a rental storage locker not commensurate with their overall client profile.

·                Client makes long-term/short-term homestay rentals in the same geographic area in which the subject resides, often accompanied by travel and food transactions to/from this location (e.g. food delivery apps, ride share apps etc.).

·                Client transacts with pharmaceutical, agricultural, or chemical supply companies that are not aligned with their stated occupation.

·                Client purchases industrial lab equipment with no obvious business need, for example pill presses and industrial pumps.

·                Client uses payment processing services to purchase essential chemicals, precursor chemicals, pill press punch dies, pill press tablet machines, or other relevant manufacturing equipment or material.

Chemical brokers breaking bad: Why pay such risky entities for toxic supplements?

·                Chemical broker makes payments to legitimate but high-risk entities known to supply precursor chemicals.

·                Client makes unusual cash deposits to a chemical company’s accounts.

·                Client leases a warehouse, a third-party logistics area, or a docking warehouse for a company that does not appear to require storage space.

·                Client operates a chemical laboratory, storage facility, or supplement processing/packaging business whose transactions are out of the ordinary for their declared business.

·                Client claims to operate a food or supplement manufacturing business, but purchases large amounts of toxic chemicals not associated with commercial food or beverage manufacturing.

Why are you using sketchy payment operations to entities without ties to your company or sector?

·                Client makes excessive transactions to payment processing companies that are not commensurate with the subject’s financial profile.

·                Client pays rent or makes real estate related transactions for multiple properties in rural or remote areas using different bank accounts.

·                Client makes frequent remittances to multiple individuals with no obvious relation to the sender located in known high-risk jurisdictions for the trafficking of drugs and/or the production of synthetic opioids.

·                Client purchases and/or sells heavy machinery/industrial equipment with no apparent business need.

Why does a small vitamin company need precursor chemicals, advanced lap equipment and heavy machinery – to a residential mailing address?

·                Client purchases and/or sells research chemicals that are precursor chemicals.

·                Client makes large money transfers to illicit cannabis companies that could be for the purchase of lab equipment.

·                Client makes purchases for the importation or delivery of heavy machinery that are inconsistent with their overall profile.

·                Client makes purchases for the importation or delivery of heavy machinery and uses a residential address as their mailing address.

Indicators of synthetic opioid distribution

Why are you making so many cash deposits and withdrawals along known drug corridors?

·                Client employed in trucking/shipping/logistics frequently makes cash deposits beyond the financial means associated with their profile especially in addition to regular payroll. These cash deposits are made in multiple locations along known drug corridors (see section on Illicit Distribution of Synthetic Opioids for known corridors).

·                Client frequently conducts point-of-sale transactions, electronic funds transfers, cash withdrawals, and/or makes travel related expenses at multiple locations along established/known drug corridors, often within the same day that is not in line with their stated occupation (see section on Illicit Distribution of Synthetic Opioids for known corridors).

·                Client frequently conducts numerous transactions with vehicle rental companies that are not commensurate with their profile and occupation.

Why do your email money transfers have such exotic names in the memo section, like ‘fenty, China girl and dragon’s breath’

·                Client makes frequent and bulk purchases of mailing materials made from post-offices and courier services, often disbursed between multiple outlets and that is not commensurate with their business activity.

·                Client travels to locations known for illicit drug production or trans-shipment points.

·                Client receives email money transfers with references to common street-names for drugs in memo section (e.g., fent, fenty, china girl, tango, dragon’s breath, bean, etc.).

·                Client purchases multiple money orders addressed to different entities such as insurance companies.

Why do you only pay for packages in cash or prepaid cards and the shipment details are so vague?

·                Client sends and/or receives packages destined to various locations including the US and Mexico.

·                Client disguises items being shipped as low-risk goods with a description such as “action figure” or vague details.

·                Client ships packages under the 1 kg weight.

·                Client typically pays for purchases in cash and/or prepaid financial products.

Why are my clients in shipping, trucking and medical supplies making so many large transactions with residential addresses and P.O. boxes?

·                Client employed in trucking/shipping/logistics frequently makes cash deposits to reloadable prepaid cards that are beyond the financial means associated with their profile. These cash reloads are made in multiple locations along known shipping routes.

·                Client uses P.O. Box, drop shipping addresses/locations, long/short-term homestay or rental locations, or empty/abandoned homes as mailing addresses.

·                Client is in the medical field and has unusual pattern of transactions (volume, value, frequency, etc.) that is not in line with the expected account profile.

·                Client makes frequent payments made for large truck rentals that are unusual for the client’s profile and occupation.

Virtual currency indicators of opioid production/distribution

Production

Why does my client have so many virtual currency transactions with Hong Kong and South Korea – with destinations in China?

·                Client routes virtual currency or wires through trading or freight forwarding companies located in intermediary jurisdictions such as Hong Kong, South Korea, and Singapore with destinations in China.

·                Client makes virtual currency or wire transfers to chemical companies located in China, Eastern Europe,
or India.

·                Client makes virtual currency or wire transfers to individuals located in China who may be associated with the export of chemicals or pharmaceutical products possibly through shared phone numbers and email addresses.

·                Client sends virtual currency or makes wire transfers to freight forwarding, logistic, or shipping companies accompanied by payments to chemical companies that are unusual for their client profile.

Distribution

Why does my client in shipping use Bitcoin ATMs so much?

·                Client employed in trucking/shipping/logistics frequently makes cash purchases on virtual currency at Bitcoin automated teller machines that are beyond the financial means associated with their profile.

·                These cash purchases are made in multiple Bitcoin automated teller machine locations along known drug corridors (see section on Illicit Distribution of Synthetic Opioids for known corridors).

 

How do you make a good STR when it comes to fighting fentanyl? Highlight suspect transactional types, regions, products purchased

With so many new indicators of possible synthetic opioids when it comes to making, moving and selling these drugs, that creates a further dilemma: how do I distill the best, most pertinent information in a way that will help law enforcement the most when creating a suspicious transaction report (STR) in Canada or suspicious activity report (SAR) in the U.S.

In short, what does a good STR look like?

Panelists also highlighted what would be considered a strong STR from the perspective of supporting law enforcement in fighting fentanyl trafficking through two actual sanitized STRs.

In the examples, the institution that filed the reports detailed a bevy of red flags indicative of illicit activity, including:

·                High risk regions: Client makes virtual currency or wire transfers to chemical companies located in China, Eastern Europe, or India.

·                High risk products: Client uses payment processing services to purchase essential chemicals, precursor chemicals, pill press punch dies, pill press tablet machines, or other relevant manufacturing equipment or material.

The STR also stated the number of payment processor accounts used and the overall amount of money spent on the chemicals and equipment, in this case tens of thousands of dollars and that some of the funds were spent on drug precursor chemicals.

The institution researched the chemicals, stating their control numbers and even related them back to their final illicit drugs, such as precursors for MDMA, barbiturates and prescription anxiety pills.

The STR went into further detail to note the scale and the scope of the potential illicit drug manufacturing operation.

The report stated that the company also purchased reagents, solvents, excipients and laboratory equipment commonly used for drug manufacturing – artificial colors, gums and powders – and a range of general lab, distillation and filtering equipment.

The final nail in the risk coffin: the STR noted other purchases including concealment shelves and hidden drawers.

In a second STR, the institution gave additional scrutiny to an operation that was engaging in virtual currency transactions – including an address known to be associated with a darknet marketplace.

Examples of darknet marketplaces include: ASAP Market (formerly ASEAN), Mega Darknet Market, Blacksprut Market, and OMG!OMG!.

Beyond the darknet markets, the individual interacted with addresses on the blockchain linked to other ransomware and fraud schemes, such as high-risk exchanges, sanctioned entities and mixing services – which exist solely to try and obfuscate virtual value transactions typically traceable on the immutable blockchain.

In the end, authorities uncovered that the individual with so many seemingly illicit transactions had been arrested, charged with drug offenses and ordered to forfeit millions of dollars in Bitcoin.

The STR ended up being eerily prescient, with the individual allegedly purchasing weapons and illicit narcotics, including cocaine, diluted fentanyl, pure fentanyl, methamphetamine and heroin for the purpose of trafficking – drugs eventually seized by authorities.

 

OSINT in the context or corporate transparency: Use multiple sources to get a deeper, richer risk perspective 

While certain businesses have a higher risk of being tied to fentanyl trafficking than others, every corporation – large or small – represents unknowns to banks holding their accounts at account opening and across the span of the relationship.

Finding out the answer to the question, how can I use open-source intelligence (OSINT) to improve corporate transparency and uncover details a company is trying to hide was one of the most popular panels at FFS 2025.

But first, what is OSINT?

In short, it is the process of collecting, analyzing, and extracting meaningful insights from publicly and commercially available data sources across the Surface Web, the Deep Web, and the Dark Web.

    It can help retexture risk in a variety of ways, including:

• Key for financial crime prevention and corporate risk assessment
• Helps uncover fraud, corruption, and undisclosed risks
• Example: Investigating a company before a merger to reveal hidden liabilities

Moreover, OSINT can be gathered from a variety of sources under a wealth of specific categories.

Here are some snapshots:

Social Media Intelligence (SOCMINT)

• Public Records
• Business Records
• Data Breaches
• Domain Registries
• News Media
• Government Records

•       Intelligence gathering techniques and sources include:

• Dark Web
• Geospatial Intelligence (GEOINT)
• Human Intelligence (HUMINT)
• Signals Intelligence (SIGINT)
• Measurement and Signature Intelligence (MASINT)

•      Free Tools

• OpenCorporates: Helps identify company ownership across jurisdictions.
• SEC EDGAR: U.S. Corporate filings.
• Wayback Machine: Allows you to access deleted or altered webpages, which can be critical when investigating fraudulent companies.
• Local State/County records (not always free)
• WHOIS

•      Paid Tools

• LexisNexis
• Pipl
• Various OSINT vendors, which give access to reliable and up to date data

•      “When you are looking at it from a corporate perspective and you have some budget, don’t always just assume that one vendor has everything,” said one panelist.

“There is a rule…that two is one and one is none. If you have two providers, that data will be very different often. You might want to consider using two providers rather than one. [One vendor] won’t have everything.”

OSINT Data Dive snapshot: What does a full spectrum OSINT query look like?

From scoping your initial target, to the presence of that entity in the physical and virtual worlds and their connections to financial crime and blacklists, here is a look at the steps needed to engage in an OSINT investigation:

Request (Incoming)

• Ø  Determine scope
• Ø  Initial assessment w/stakeholder

Review entity

• Ø  Determine ownership
• Ø  Determine locations
• Ø  Any sanctions concerns
• Ø  Corporate history

Adverse media review

• Ø  Entity
• Ø  Individuals

Secondary review

• Ø  Connected entities
• Ø  Connected individuals
• Ø  Concerns with these individuals/entities

Web presence

• Ø  Where hosted (high risk or sanctions related)
• Ø  Stock images or real
• Ø  Passive DNS located previously unknown sites • Malicious content on websites (malware etc…)

Complete assessment

• Ø  Seek feedback

One source of OSINT are sites tied to what panelists called Russian password-stealing malware that secretly purloin data from multiple domains.

In those sites, users can peruse breached data and passwords, including for some escort sites.

Panelists noted that by cross-referencing certain data points, users can uncover potential human trafficking.

Investigators can uncover sex buyers as they will have multiple logins to different sites while leaving the same email and phone number.

Illicit sex sellers, conversely, will have multiple logins to the same domain and then an associated email to a login and password so that potential Johns can review their offer and decide to reach out.

 

Soaring scams and brazen fraudsters seem to be the norm, but when did the avalanche start?

While OSINT can help public and private sector fincrime fighters better uncover buried risks tied to illicit entities, it seems a blunted weapon in the fight against a rampaging fraud juggernaut targeting people, businesses and virtual value assets.

But when did this explosion of fraud and endless scam texts across your email, phone and text start?

And from the perspective of bank and fraud countercime teams, how can you better make your bank staffers and customers allies in this fight?

In one word to describe when things started to really go south in terms of the fraud epidemic: the pandemic, according to speakers during ACFCS’ Future of Fincrime Skills session: “Fullz, Walkers and Innys - Navigating the Modern Fraud Ecosystem.”

“I would say it was the pandemic,” said Frank McKenna, Chief Fraud Strategist and Co-Founder of Point Predictive and host of the “Frank on Fraud” podcast.

“Everyone started working from home and they were online a lot more. You saw these [fraud] groups really flourish during the pandemic and they have not slowed down. They in fact have ramped up.”

From romance scams to lottery scams, investment scams to recovery scams – scammers saying they will help scam victims, only to victimize them again – these fraud schemes have seemingly gone from a minor annoyance to a daily deluge across every technological touchpoint.

The session highlighted that some countries – such as those in India and Southeast Asia – have industrialized scam call centers, in some cases staffing them by duping desperate and impoverished foreigners, more victims victimizing victims.

But in recent months, some countries have finally decided to go after these scam centers, according to the Associated Press.

The news agency reported that a “new crackdown on online scam centers has led to over 7,000 people from around the world being held in a Myanmar border town awaiting repatriation.”

The crackdown entailed coordination between multiple countries, including Thailand, Myanmar and China.

The actions followed Thai Prime Minister Paetongtarn Shinawatra's visit to Beijing in February, where she told Chinese leader Xi Jinping that Thailand would “act against the scam networks that have drawn in hundreds of thousands of people,” according to AP.

As panelists noted in this and other events, the individuals in these operations are often victims themselves, “lured under false pretenses to work in scam centers in Myanmar, Cambodia and Laos, where they financially exploit people around the world through false romances, bogus investment pitches and illegal gambling schemes.”

As so many of these scams touch the formal financial system, attendees naturally asked the question: how can I keep my bank staffers – in and out of dedicated AML fraud fighting teams – full of focus and fervor and gain the ear of the C-suite in what feels like an against all odds fight.

For Hailey Windham, the Financial Crimes Program Manager at SAFE Federal Credit Union, one way is sharing the tactics of scammers and the emotional stories of victims with her team – and employing a bit of social engineering herself.

“In my internal newsletter, I change it up,” she said. “Make a crazy title and get them to read it. Use a click bait title and use real world scenarios. [Don’t be bland]. Tell a story. Tell what happened.”

“Let [your team] know how [the victims] were targeted, how much money they lost and what were the repercussions of falling for this scam,” Windham said. “How we communicate this out [to internal bank teams and customers] has to change.”

But the panel also pointed out that some countries are taking a whole-of-government approach to fighting domestic fraud and foil foreign scammers – with stunning early results.

Case in point: Australia with its recently passed Scams Prevent Framework – a piece of legislation aimed at losses affecting more than 600,000 residents to the tune of nearly $3 billion, a frightful figure triple what it was just three years ago. 

While eye-watering, the sum is just a fraction of global scam losses.

Research from the Global Anti-Scam Alliance (GASA) found global victims lost more than $1 trillion to scams in 2024 alone.

Hence the need for desperate measures to counter this rising scourge.

The result: Australia introduced the Scams Prevention Framework (SPF) Bill 2024 into the Parliament in November to establish a multi-sector, cross-government defense, reaction and intelligence network.

The tacit goal was to create what it called “world-leading protections against scams,” according to a just-released guide on how to implement and comply with the new requirements. 

“This will better protect consumers and make Australia one of the toughest places in the world for scammers to target.”

The finalized framework, swiftly passed in February is a “key pillar of the Government’s response to the rising threat of scams” and “lifts the bar across the economy by setting out consistent and enforceable obligations for businesses in key sectors where scammers operate,” according to the guide.

Since 2022, Australia has made it a country-wide mission to counter scams targeting the country’s residents and businesses, investing nearly $200 million across a bevy of avenues and illicit touchpoints, including by:

•                 Establishing the National Anti-Scam Centre (NASC) as a partnership between regulators, law enforcement and industry to detect, disrupt and prevent scams.
•                 Creating a “scam czar,” similar to a drug czar or terrorism czar in other countries.
•                 Establishing a registry for SMS sender IDs to prevent criminals impersonating a well-known brand or service.
•                 Empowering the ability of government regulators to take down scam websites.
•                 Requiring certain financial services companies, internet providers, telecommunication firms and social media sites to take “reasonable” steps to remove scammers from their platforms and respond to complaints – or face fines of up to $50 million.
•                 Funding a campaign that will improve community awareness of scams and help Australians identify, avoid and report scams.

The efforts are already bearing fruit – with a stunning drop in scams and related losses.

The newly minted NASC stated that scam losses reported to Scamwatch – a new entity run by the NASC to collect reports about scams – plummeted by more than 40 percent in the first full year of the public-private initiative.

“I have been raving about Australia…because what they are doing is really really positive,” said one panelist during the session.

“It provides optimism for the future and it provides a blueprint for how we can actually fight back against fraud and cyber-fraud in general. This is a blueprint to show the rest of the world…how to make a difference.”

 

 

When it comes to GenAI and fincrime compliance is it doing more harm than good?

No doubt, in that fight against fraud, Australia is using cutting edge technology, urging innovation and engaging the incredible powers of more approachable generative artificial intelligence.

But that comes with the acknowledgement that criminal groups are also using these same powers for ill, fake voices, pictures and videos, to dupe and snare more victims. 

The query then becomes: what good has artificial intelligence and generative AI brought to the compliance function?

And is that positive outweighed by that criminals can do with that selfsame technology?

Those were just some of the questions tackled by speakers on Day Two of ACFCS’ Future of Fincrime Skills 2025 virtual summit during the panel: “AI in Financial Crimes Compliance: Balancing the Good and the Evil.”

The short answer: it’s a bit of an arms race right now.

Panelists noted that they now have the power to create on-the-fly algorithms to uncover trends in things like human trafficking – a dynamic typically reserved for pricey vendors – with one speaker noting he was able to streamline an algorithm that took three hours to extract data down to 30 seconds.

Fincrime compliance officers can also shrink down the time it takes to research and get data in a format that more quickly can populate a suspicious activity report (SAR) narrative section.

But now, AML and fraud teams must spend more time fact checking the data AI engines produce – cognizant that when these virtual servants can’t find what you want, they simply make it up, complete with fictitious citations.

On the negative side, however, criminals can use even snippets of voices to “deepfake” a person – potentially outwitting historical transactional checks and balances, according to Mitch Farsad, the AML Director of the FIU at Stifel Financial Corp.

“These days…the criminals, the bad actors, they can take a voicemail of someone…and just from that little two sentences of a voicemail, they can create an AI model that will use that same voice, the same way it talks, the same pauses, the same everything and now they can make phone calls with that,” he said.

“So, the reason I think about that is I know that a lot of firms, when the client wants to do a wire disbursement, they will do some type of voice call back, verbal verification, and I keep on saying that it is just a matter of time before that is a thing of the past.”   

 

AML regulators sound off: In a world of AI, what do examiners want to see in terms of compliance programs, processes? 

What is not something of the past is the ongoing challenge of keeping current in your job as an AML professional by sharpening your knowledge of emerging criminal trends and typologies, according to panelists during a day two compliance jobs’ panel.

The speakers looked at how AML teams can better view their requirements to run a stout AML program, create intelligence for law enforcement and appease picky regulators – because the speakers were current or former regulators themselves with nearly half a century of experience between them.

Even in a world of more understandable and approachable genAI technologies, panelists agreed that one of the most powerful ways to become a better AML professional – and impress regulators – is by boning up on your knowledge of how fraud schemes can penetrate compliance defenses and victimize customers.

Historically, several banks that were the financial epicenter of, for instance, massive Ponzi schemes ended up having regulators fine them millions of dollars for blunders under the auspices of lax AML programs and broader “safety and soundness” failings. 

When an examiner sees that a fraudster co-opted the business line, frustrated the fraud group and evaded the AML team – in some cases for years, the first thing an examiner typically thinks is: what is the process failure that allowed this fraud to happen at the institution.

“You have to think to yourself: processes,” one panelist said. “Is it systemic? Where is the breakdown in this process? Is it internal controls? Is it in training? Is it in resources? Is it audit that just missed it?”

“Now that I found the fraud, what was the root cause. That’s how an examiner thinks,” the person said.

“It’s not just about finding that one bad guy or that one criminal ring. From an exam standpoint, [the question is] where is the breakdown in the bank so that a similar typology [of fraud] will not happen again.”