Risk Assessment Updates

Risk Assessment Updates

Spotlight Keywords:
Cattle Laundering
Terrorist Financing
Conflict Financing
Lake Chad Basin
Boko Haram
Environmental Crime
Financial Institutions
Money Laundering
Land Conversion
Supply Chain Risk

Cattle-laundering, conflict, and terrorist financing in the Lake Chad Basin

Recent reports have found that cattle rustling – the forceful theft of livestock for illicit commercial gain – has become increasingly prevalent in the Lake Chad Basin in Africa, linking the cattle industry with conflict and terrorist financing. Between 2015 and 2024, the incidences of cattle rustling by Boko Haram at the borders of Cameroon and Chad have increased nearly 800%, from two incidences reported in 2015 to 158 in 2024. These incidences have also been accompanied by increased fatalities, with 20 deaths linked to cattle rustling in 2024.  

According to experts, cattle rustling is a major source of funding for armed groups, with the stolen cattle used to buy weapons and supplies. Tactics range from direct theft to illegal livestock taxes on pastoral communities, and are becoming increasingly elaborate. In some cases, the stolen cattle are ‘laundered’: taken to Nigeria, the region’s biggest cattle market, to be exchanged for other ‘clean’ cattle that are then taken back to Cameroon for sale.  

The risks for the financial system

This illustrates an increased risk for financial institutions exposed to the cattle industry in the Lake Chad Basin through direct and indirect activities like investments, loans or insurance, or through their supply chain when it comes to financial crimes such as conflict and terrorist financing, money laundering, and other human rights abuses. This case also emphasises the risks posed to the financial system. Indeed, as found in our 2024 report, ‘Financial Crimes and Land Conversion: Uncovering Risk for Financial Institutions’, almost half of financial institutions surveyed reported operating with or in high-risk sectors or areas.  

In our recent update of the Land Conversion and Financial Crime Risk Assessment, created together with WWF, in which we outline the financial, environmental and serious organised crime risks and associated human rights risks related to the production of certain commodities in particular countries, we have accordingly updated the risk rating for the cattle industry in Cameroon and Nigeria to red, which indicates a high risk for terrorist and conflict financing Further information on our risk rating determination is available here.

(Source: Themis and WWF-UK, Land Conversion and Financial Crime Risk Assessment)

Managing risk better with a new open access platform for financial institutions

As risks are constantly changing and evolving, we undertake regular updates to the Risk Assessment. Other key changes in this round of updates to the Risk Assessment include, for example:  

  • new data on the prevalence of carbon credit fraud in Brazil’s timber industry,
  • official complaints from Ghanian cocoa growers on the industry’s use of child labour and dangerous pesticides,
  • sanctions imposed by the US and UK on an international gold smuggling network in Kenya.  

Complete details of our recent updates can be found here, and a record of changes to risk ratings over time are also available here.

Finally, we have also updated our Environmental Crimes Financial Toolkit, also developed  with WWF, to include a new search function, which streamlines the process of searching for key case studies at the intersection of financial and environmental crime.  These case studies provide concrete insights into financial and environmental crime risks and have a dedicated section in the toolkit. To try it out for yourself, visit the website here.

Blog Posts

SpotLight

Stay on top of the ever-changing financial crime landscape by accessing the latest information on emerging criminal techniques and the risks associated with carrying out business with particular industries or in particular jurisdictions.

Back to School Reading List

August 2025
Back to School Reading List: Essential Reads on Financial Crime

We’ve handpicked a selection of standout books our team discovered over the summer—perfect picks to kick off the “back-to-school" season. These compelling reads offer deep insight into financial crimes, the systemic vulnerabilities they exploit, and their far-reaching consequences.

...

AI ROI

August 2025
The CFO’s Guide to Smarter Investments in Financial Crime and Beyond

AI is fast becoming a high-ROI tool in financial crime and compliance. From cutting costs and boosting efficiency to enhancing resilience, strategic AI investments are helping CFOs do more with less - transforming risk management and unlocking new value across the financial sector.

...

Money Laundering & Terrorist Financing

July 2025
The UK’s 2025 National Risk Assessment on Money Laundering and Terrorist Financing

The UK’s latest National Risk Assessment (NRA) reveals how money laundering and terrorist financing are evolving—and how the UK is fighting back. A vital guide for AML policy, it arms businesses with intelligence to spot risks and stay protected.

...

OFAC’s 50 Percent Rule

July 2025
Beyond the Surface: Why OFAC’s 50 Percent Rule Demands Deeper Due Diligence

Many clients have heard of the OFAC 50 Percent Rule but aren’t sure how it affects them. It’s far-reaching, with hidden sanctions risks. This post explains the rule, why it demands deeper due diligence, and steps to identify and mitigate those risks.

...

Dirty Money

June 2025
UAE Steps Up the Heat on Dirty Money

In June, the EU removed the UAE from its list of high-risk jurisdictions from an AML perspective, signaling growing international confidence in the country’s financial crime oversight.

...

Risk Assessment Updates

February 2025
Risk Assessment Updates

New updates to the Land Conversion and Financial Crime Risk Assessment link environmental harm to financial crime. Cattle rustling in Nigeria and Cameroon is now red-rated, with added risks on carbon credit fraud, child labour, mining corruption, and gold smuggling.

...

Modern Slavery

October 2024
What is Human Trafficking?

An overview of modern slavery, distinguishing between human trafficking, smuggling, and forced labor. It highlights the global prevalence of exploitation and the importance of understanding these definitions to combat such crimes.

...

Safeguarding the Skyline

August 2024
Ensuring Financial Transparency in Dubai Real Estate

Dubai’s $160B foreign-owned real estate market faces money laundering risks. The UAE now requires reporting of property deals over AED 55K via REAR. Criminals like Daniel Kinahan have exploited property to hide illicit funds, underscoring the need for strict compliance.

...

Human Trafficking

August 2024
Human Trafficking & the Digital World

Examines how digital platforms and cryptocurrencies facilitate human trafficking, allowing traffickers to operate anonymously and at scale, posing challenges for law enforcement.

...

Nexus Sanctions

August 2024
Exploring the Nexus of Sanctions and Trade-Based Financial Crime in Hong Kong

Investigates how sanctions intersect with trade-based financial crimes in Hong Kong, highlighting the complexities businesses face in navigating regulatory compliance.

...

Uncountable Costs

May 2024
The Hidden Harm of Financial Crimes on Mental Health

Financial crimes cause more than economic harm—they hit mental health too. UK data shows 60% of fraud victims face distress; Ghana research links corruption to anxiety and depression. This blog calls for tackling both psychological and financial impacts.

...

International Women's Day 2024

March 2024
International Women's Day 2024

Environmental crime worsens gender inequality, driving violence, trafficking, and hardship for women—especially in regions like the DRC and Peru. Women defenders face abuse, and climate change deepens risks like water scarcity, child marriage, and health threats. Tackling these crimes is key to protecting women’s rights and safety.

...

Beyond Risks

February 2024
Unleashing AI's Potential for Good in Financial Crime Prevention

AI is transforming financial crime prevention—improving detection, reducing costs, and streamlining compliance. Generative AI and graph networks boost due diligence, while ethical, human-guided use counters criminal misuse. Themis champions tech-human collaboration.

...

AML

August 2023
How Fuzzy Is Your Logic?

Explores the application of fuzzy logic in Anti-Money Laundering (AML) systems, emphasising its role in improving name-matching accuracy and reducing false positives, thereby enhancing compliance efficiency.

...

Book Review

July 2023
Book Review : 'Tree Thieves: Crime and Survival in the Woods' by Lyndsie Bourgon

This book focusses on the challenges faced by law enforcement in North West USA and in British Columbia to combat illegal logging, as well as those of the timber-industry communities established since the late 19th century to maintain meaningful and financially viable lives.

...

Progress Applauded in the UAE

July 2023
Progress Applauded in the UAE's Efforts to Stamp Out Financial Crime

The FATF has highlighted the UAE’s progress in fighting financial crime. Its third enhanced follow-up report upgraded three recommendation ratings for the country, marking a step forward in meeting international standards.

...

Lebanon's Economic Woes

July 2023
Lebanon's Economic Woes

Lebanon’s economic collapse, fuelled by debt, corruption, and instability, has led to hyperinflation and greater financial crime risk. In Oct 2024, the FATF grey-listed Lebanon. The country pledges a two-year reform plan to boost transparency and restore investor confidence.

...

Weeding Out Confusion

June 2023
A Guide to the Legality of Foreign Cannabis Proceeds in the UK

The UK treats profits from legal overseas cannabis businesses as criminal property under the Proceeds of Crime Act. Few cases qualify for exceptions, creating a legal grey area—so anyone handling such funds should proceed cautiously and seek legal advice.

...

The Economic Crime Plan 2023-26

April 2023
The Economic Crime Plan 2023-26

The UK’s 2023–2026 Economic Crime Plan commits £400M to tackle money laundering, kleptocracy, and fraud, with reforms to Companies House, crypto, and sanctions. Progress is clear, but critics urge more urgency and funding. Success depends on public-private collaboration.

...

Suspicious Activity Report

March 2023
An Exception to Tattle Tailing

Suspicious Activity Reports (SARs) are key to fighting financial crime, with 42% of fraud found via tip-offs. Rising UK SARs and account freezes show their impact. Themis urges strong reporting systems and whistleblower protections to foster transparency.

...

Corrupt Elites

March 2023
The Murky World of Family, Offshore Companies, and 19th Century London Taverns

Corrupt elites still exploit the UK property market via offshore structures and relatives to hide assets. Over 18,000 firms remain non-compliant. With cases of children holding luxury homes, Themis calls for tougher enforcement as new UK and FATF guidance target transparency gaps.

...

High Corruption Levels

March 2023
Do Countries With Higher Corruption Levels Perform Worse on DEI?

Corruption undermines sustainable development, financial integrity, and DEI. A Themis–Denominator study links lower corruption to higher DEI scores. Marginalised groups, especially women, suffer most. Promoting diversity and transparency is key to fairer societies.

...

The Adani Group

March 2023
The Reckoning of the Adani Group

Hindenburg Research accuses India’s Adani Group of fraud, alleging stock manipulation, shell firms, and nepotism—halving Gautam Adani’s net worth and shaking investor confidence. The case highlights how financial crime can roil markets and the need for strong due diligence.

...

A Turning Point for ESG?

March 2023
The EU's Corporate Sustainability Due Diligence Directive

Supply chain failures have linked firms like Inditex and Skechers to forced labour and reputational risk. The EU’s CSDDD will require large companies to address human rights and environmental harms. Themis offers tools to assess suppliers and fight modern slavery.

...

World Wildlife Day 2024

March 2023
World Wildlife Day

On World Wildlife Day and CITES’ 50th year, Themis reflects on tackling illegal wildlife trade—the 4th largest financial crime. Laws, AI, forensics, and global cooperation drive change, but shifting demand, like ivory to hippo teeth, shows challenges remain.

...

Puppy Smuggling

February 2023
Make Sure to Vet Your Dog Breeder

Puppy smuggling in the UK has surged post-pandemic, with organised crime exploiting demand and loopholes to import sick or underage dogs. Despite new laws, enforcement gaps remain. Themis urges buyer vigilance—tools like Themis Search can help spot breeder risks

...

Breaking Hearts & Banks

February 2023
The Dark Side of Valentine's Day

Romance scams rose 30% in 2022, with victims losing £8,234 on average—especially men and those aged 65–74. Scammers use fake profiles and emotional manipulation. Themis urges due diligence in dating; tools like Themis Search can flag risks and help platforms protect users.

...

The Crypto War

May 2022
Digital Currencies and Financial Crime in the Russia-Ukraine Crisis

Crypto plays roles in both social good and crime—over $50M has aided Ukraine, but bad actors use it to evade sanctions and launder funds, notably via the UAE and Central African Republic. Themis calls for stronger due diligence and compliance to curb misuse.

...

Human Trafficking

March 2022
A Catalyst for Human Trafficking Emerging Risks Facing Ukrainian Refugees

The Russian invasion of Ukraine has heightened trafficking risks for women and children. Over 2.5M flee, with traffickers exploiting chaos, especially in Moldova, Poland, and Italy. The OSCE urges swift action to warn refugees of false offers and protect them.

...