Anti-Money Laundering (AML)
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Fraud Management & Cybercrime
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Fraud Risk Management
ACAMS Says Investigators Need Better Data, Architecture and AI-Based Detection

The financial system has a trust problem driven by artificial intelligence and deepfakes. Investigators looking to prevent fraud and other financial crimes will only face more challenges as criminals find new ways to use AI to swindle, according to the Association of Certified Anti-Money Laundering Specialists’ Global AFC Threats Report 2026.
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The rapid acceleration of AI, deepening geopolitical fragmentation and the increasing sophistication of criminal networks, are all converging to create a perfect storm for the world’s anti-financial crime professionals.
“Baseline expectations now have gone from down here to up here,” said Justine Walker, executive vice president of thought leadership at ACAMS. “What people were doing two years ago is not going to be sufficient for what they need to be doing in two years’ time.”
The group surveyed 1,400 compliance professionals worldwide, the majority of whom work in the financial industry.
The report finds that for the third consecutive year the malicious use of generative AI is the most significant risk in fighting financial crime, with 75% of survey respondents saying AI poses high or very high risk. AI is also enabling “fraud as a service” platforms that help less-sophisticated criminal actors pull off elaborate and convincing heists, further complicating defense.
The rise of AI is shifting how anti-financial crime teams are prioritizing resources, and 84% said that they’re focused on fighting scams and fraud against individuals.
AI-powered identity fraud was ranked second as everything from holograms to deepfakes are helping to erode trust in identity verification systems. Biometric checks and document security features are no longer surefire means of verification.
“The deepfake scenario now is just making it so, so complex,” Walker said. Whereas due diligence in the past may have involved looking at a passport or bank statements, in today’s climate checking documents is “essentially useless.”
Institutions are exploring new fraud detection technology, including behavioral pattern analysis, device and contextual intelligence and multi-layered verification strategies.
Yet while organizations scramble to combat AI-driven attacks and adopt AI-based defense strategies – 56% say they’re piloting AI tools now – many are hampered by their own internal infrastructure. Without high-fidelity, unified datasets, AI models remain prone to bias and high false-positive rates, further stretching already thin compliance resources.
“Over half of people are saying that outdated data and legacy IT systems are high or very high risk to the AFC programs,” Walker said.
The industry also is challenged by the lack of cohesion in regulation and escalating geopolitical tensions fueled by fluctuating tariffs and sanctions. While 72% of respondents said they expect significant changes to AI regulations in the next 12 months, 70% said they also expect cryptocurrency asset regulations to change.
This fractured response is coming up against an underground banking system that has gone digital faster than defenses have adapted. Digital hawala networks using encrypted messaging systems and cryptocurrency – which ACAMS calls “digital veins”- shell companies, and shifts of illicit activity to weaker jurisdictions are helping criminal organizations thrive.
“The old hawala network is really becoming much more technologically savvy,” Walker said, adding that companies aren’t ready to defend against them. ACAMS said that half of those polled at its 2025 ACAMS Las Vegas Assembly said digital-asset skills gaps were their most critical shortcoming.
“There is no global agreed approach for how to respond,” Walker said. “Criminals are just exploiting regulatory weaknesses.”
For CIOs, a robust anti-financial crime strategy hinges upon on data architecture, system integration and AI readiness. Data modernization is an imperative to enable AI, fraud detection and sanctions monitoring, and static identity and security systems need to be upgraded to adaptive, intelligence-driven systems.
“It’s not so much the technology, it’s actually having the right data to really utilize new technology tools,” Walker said. “Resilience is the defining capability for those seeking to thrive amid disruption.”
