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This week, the UK government published its latest National Risk Assessment (NRA) of money laundering and terrorist financing. The assessment offers a sharp and timely snapshot of how financial crime is evolving—and how the UK is fighting back. As criminals become smarter and more adaptable, the NRA offers a playbook for staying ahead. It is a critical tool for informing the country’s AML policy and regulation, while also giving businesses the intelligence they need to spot risks and protect themselves.
Buy our brand-new UK Country Risk Briefing for further insights into the 2025 NRA and the broader financial crime risk landscape in the UK.
The NRA draws on a broad range of expertise—from the private sector, academia, and open-source intelligence, to insights from law enforcement, regulators, and across government—to provide a comprehensive and informed picture of the UK’s financial crime risks. It reflects the deep expertise and commitment of partners across both the public and private sectors, including supervisors, regulators and law enforcement, whose efforts are vital to safeguarding the integrity of the UK’s financial system and economy.
Since 2020, the UK government has taken significant and sustained action to tackle money laundering and broader economic crime. Central to this effort is the Economic Crime Plan 2023–26 (Economic Crime Plan 2), which sets out a whole-system approach to combatting economic crime. Backed by approximately £115 million in annual funding, the plan builds on the foundations laid by its predecessor and introduces targeted action to address the highest-risk areas identified in the previous NRA.
Combatting corruption and illicit finance is also a key priority within the UK’s foreign policy, given the widespread harm these threats pose to international stability, security, and prosperity. In November 2024, the UK launched its Illicit Finance campaign, aimed at demonstrating global leadership underpinned by strong domestic reforms. The campaign focuses on identifying and addressing the vulnerabilities that enable corruption and illicit finance, both at home and abroad.
Looking ahead, the government is set to publish a new Anti-Corruption Strategy in 2025. This will set out measures to strengthen the UK’s resilience to corruption and reduce domestic vulnerabilities, thus helping to prevent corrupt actors from exploiting the UK’s systems and supporting global efforts to disrupt corrupt networks.
The UK has also continued to deepen its partnerships with other countries, focusing on operational cooperation to tackle shared threats. In addition to providing technical and operational assistance across key jurisdictions, the UK has also invested in strategic partnerships. For example, the UK and UAE are working to deliver on the UK-UAE Partnership to Tackle Illicit Financial Flows. The partnership aims to increase judicial co-operation and align approaches to illicit finance. This includes the work of the Combined Anti Money Laundering Operational Team (CAMLOT), a joint initiative designed to tackle money laundering operations and identify hidden financial networks tied to illicit activities.
The NRA provides a detailed overview of how different sectors are exposed to financial crime risks. It is intended to help firms, supervisors, and stakeholders both within and outside regulated sectors to understand their vulnerabilities and the broader context in which these risks occur.
Each sector’s risk rating is determined using the “MoRiLE methodology”—which assesses the vulnerability of the sector, the scale of the threat, and the effectiveness of current mitigation efforts by both the sector itself and government.
AI: A Double-Edged Sword. While the current use of artificial intelligence (AI) in money laundering is not yet widespread, early signs suggest it is already being exploited by criminals in a number of concerning ways. Engagement between law enforcement and the private sector has uncovered examples of AI being used for synthetic bank account creation, phishing and impersonation attacks, and fraudulent onboarding of money mules.
Looking ahead, AI has the potential to supercharge existing money laundering methods. Possible future misuse includes AI-enhanced identity theft, automation of mule recruitment and fund layering, and using AI to identify and bypass AML controls.
At the same time, AI presents major opportunities to strengthen defences. Financial institutions and law enforcement agencies are already exploring AI-driven tools to detect suspicious patterns, flag high-risk transactions in real time, and improve data analysis. For a deeper look into how AI can be leveraged to combat financial crime, check out our latest white paper on AI and Financial Crime: State of Adoption.
Football: A Growing Target for Illicit Finance. Football is more than just the UK’s national sport—it’s a global economic force. Its financial scale, combined with high visibility and diverse ownership models, makes football an appealing arena for both legitimate investors and criminal actors alike.
While top-tier clubs thrive, many lower-tier and even mid-level clubs face ongoing financial difficulties, often operating under significant debt and pressure to remain competitive. These vulnerabilities create openings for exploitation by individuals and networks seeking to launder criminal proceeds and use clubs to generate further criminal profit. For a closer look at financial crime risks in the football industry, check out our briefing note Foul Play: Financial Crime and the World of Football.
Casino Money Laundering Risks. White-label partnerships in the remote casino sector present notable money laundering vulnerabilities. In the past, some white-label arrangements involved gambling operators relying on unlicensed third parties to handle parts of their compliance responsibilities. While the licensee remained legally responsible for compliance, oversight was sometimes lacking. Although such arrangements are now less common, risks persist—especially when white-label providers manage large numbers of websites. A failure by one remote casino to control money laundering risks linked to their white-label partnerships could affect a wide network of sites.
Moreover, allowing peer-to-peer poker through remote casino platforms also increases money laundering and terrorist financing risks, as it enables direct exchange of illicit funds between customers. The use of VPNs further complicates risk management, as they can mask customers’ true locations. This allows individuals in higher-risk jurisdictions to appear as if they are operating from the UK, undermining geographical risk controls.
These key watchpoint industries highlight how rapidly evolving technologies and high-value sectors can become flashpoints for financial crime. These risks demand proactive attention, strong regulation, and continued cooperation between public and private sectors to stay ahead of emerging threats.
For practical, up-to-date insight into the UK’s financial crime landscape, buy and download to explore our brand-new UK Country Risk Briefing. Drawing on the 2025 NRA, FATF evaluations, regulatory developments, and in-house research, the factsheet provides:
Visit our Country Risk Briefing page, by clicking on the below link:
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.
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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 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.
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.
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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.
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.
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.
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.
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.
Examines how digital platforms and cryptocurrencies facilitate human trafficking, allowing traffickers to operate anonymously and at scale, posing challenges for law enforcement.
Investigates how sanctions intersect with trade-based financial crimes in Hong Kong, highlighting the complexities businesses face in navigating regulatory compliance.
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.
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.
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.
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.
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.
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 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.
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 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 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 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.
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.
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.
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.
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 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
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.
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.
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.
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