You don’t need to be a cyber security expert, but you do need to be in the loop. Cyber crime and financial crime now go hand in hand. For AML compliance, this creates a shift in how you approach detection, prevention, and reporting.
Money launderers are increasingly using the proceeds of cyber crime – such as ransomware payments or stolen card data – to move funds through the financial system. That means your monitoring systems need to be tuned into more than just traditional red flags. You also need to be aware of indicators tied to account takeovers, synthetic identity fraud, money mule accounts, and compromised business emails.
One practical change is reviewing your processes. Are your monitoring rules still based on assumptions from five years ago? If your triggers are only picking up certain high-risk profiles or jurisdictions, you’re probably missing cyber-enabled laundering. For example, criminals might move stolen funds through digital wallets or prepaid cards that don’t look suspicious unless you understand the underlying fraud.
You also need to build stronger links with your cyber security team. Too often, AML and IT work in silos. If your compliance alerts aren’t being cross-referenced with data on cyber incidents – like phishing attempts or unusual access patterns – you’re missing half the picture. Consider setting up regular check-ins or shared dashboards that allow for real-time information sharing between teams.
Reporting is another area that needs to be tightened. If you’re submitting SARs (Suspicious Activity Reports) without including indicators of cyber crime, you’re giving law enforcement only half the story. Make sure to reference things like IP addresses, suspicious domains, or known malware campaigns if that information is available. It makes your reports more actionable.
Training matters too. Your frontline staff are the first line of defence, but only if they know what to look for. Make cyber-enabled fraud a standing item in your AML training sessions. Show them how to spot signs of fake identities, mule recruitment, or socially engineered scams. Give them examples that are relevant to your business, not just generic case studies.
Regulators are watching this space closely. There’s growing expectation that regulated businesses can spot and respond to the convergence of cyber and financial crime. That includes having the right risk assessments, policies, and procedures in place – and being able to show how you’re adapting to new threats.
Cyber crime isn’t something you wait to react to. It needs to be part of your risk assessments from the start – when onboarding clients, updating monitoring rules, and designing controls. The aim isn’t to become an expert in cyber defence, but to build enough awareness into your AML programme so you’re not the weakest link in the chain.