Money Laundering Bulletin

The goal of identifying alerts in transaction monitoring output that will translate into suspicious activity reports, long a labour-intensive triage process, may, Keith Nuthall finds, be set for full and effective automation through AI, but the benefits will only be realised if law enforcement is geared to manage and integrate more, higher quality filings with other criminal intelligence.

The Financial Action Task Force (FATF) has released comprehensive 340-page guidance designed to boost the seizure of criminal assets by governments, law enforcement, prosecutors, courts and asset managers.

BaFin, the Germany financial services regulator has ordered Frankfurt-based JPMorgan SE to pay €45 million (US$59 million) after it failed to submit timely suspicious transaction reports.

Coinbase Europe, wholly owned by Coinbase Global, Inc, the world's third largest cryptocurrency exchange by volume, has been censured and ordered to pay a civil monetary penalty of €21,464,734 (US$24,830,190) by the Central Bank of Ireland (CBOI) for flaws in transaction monitoring and delayed filing of suspicious transaction reports (STRs) dealing with trading on the darknet, in illegal narcotics, malware, ransomware, child sexual abuse material, money laundering, scams and potential breaches of US sanctions. The misconduct occurred between 23 April 2021 and 19 March 2025.

We are social beings (generally) so it can feel lonely and hard to stay positive, to do your best in a line of work still too often cast as business obstruction. The best answer to any sense of isolation is to seek out others who can empathise, recognise the pressures and demands, who may, indeed, have confronted the exact same issue you currently face. The AML profession, although relatively new, already has deep collective experience of combating crime and meeting regulatory standards. Keith Nuthall looks at where to go for guidance, support, and, chances are, to make new friends.

On 10 November it was widely reported that police forces in the UK had conducted a four-week campaign of raids on high-street shops and businesses engaged in illegal activity. In collaboration with partners including trading standards, HM Revenue & Customs and the Immigration Service, police moved against barbershops, mini markets, nail salons and car wash operators.

AML architecture is a story of rapid development and the cracks are everywhere apparent. Even if possible, would it be wise to level the ground and start afresh, learning from past experience, and how, realistically, should the existing edifice be altered, adapted and so made more fit for purpose? Paul Cochrane and Keith Nuthall gauge informed opinion.

Criminals, always seeking new ways to shift and infiltrate their funds into the legitimate financial sector, have seized on cryptocurrencies as global alternatives to fiat money - enabling fast, cost-effective, efficient transfers. Keith Nuthall finds that gaps in legislation, controls and constant innovation mean law enforcement, firms and regulators are in continual catch-up.