Regulatory Updates

Money laundering and terrorist financing surged in 2025, both in the U.S. and globally, with 2026 showing little sign of reprieve. Crypto-linked illicit flows spiked to record levels, reaching an estimated $158 billion in laundered funds worldwide in 2025, an all-time high that more than tripled 2024’s total.¹

Traditional channels like cash couriers, shell companies and banks still account for hundreds of billions in dirty money, but cryptocurrency (or “crypto”) networks saw the steepest rise. However, enforcement lagged behind the surge, especially in the U.S., where global anti-money laundering (AML) fines and penalties declined from prior years amid deregulatory trends and regulatory staff reductions.

Longstanding United Nations Office on Drugs and Crime (UNODC) and International Monetary Fund (IMF) estimates place annual global money laundering at $800 billion to $2 trillion, equivalent to 2%–5% of global GDP, while a recent 2025 Napier AI analysis estimates broader illicit flows at $5.5 trillion draining approximately 5% of global GDP, a figure that underscores the escalating scale of these threats.^2,3

Illicit financial flows in the U.S. are rising sharply, driven by both traditional and digital channels. The U.S. Treasury estimates that up to $300 billion is laundered annually through the U.S. financial system, while illicit cryptocurrency transactions surged to the highest level in five years.⁴ The 2025 analysis by Napier AI estimated that almost $730 billion is laundered annually in the U.S., equivalent to about 2.5% of U.S. GDP.⁵

Key factors behind this trend include the exploitation of regulatory gaps and loopholes for digital assets, uneven oversight across jurisdictions and the growing use of advanced technologies. The rapid adoption of cryptocurrency and the increasing sophistication of money laundering techniques, often powered by artificial intelligence (AI) and automation, have made it easier for illicit actors to move funds undetected. According to Daniel Stipano, Head of AML/CFT for Davis Polk, “We are in a time where the global threat environment has never been higher, largely due to AI and other forms of technology.” This article examines the U.S. and global trends in money laundering and terrorist financing in 2025 and early 2026, reviews major enforcement actions, analyzes the drivers behind the rise in illicit finance and outlines potential solutions, including technology-enabled defenses, to combat these evolving threats.

 

New Money Laundering Playbook: Go Digital

Globally, most laundered money flows through traditional methods like banks, cash couriers, brokerage firms, shell companies and trade-based schemes, handling hundreds of billions to trillions in illicit transactions annually and accounting for the bulk of flows. While crypto represents a fraction of overall flows, it represents the fastest growing segment as more heavily regulated sectors face regulatory and monitoring constraints, limiting their growth as laundering avenues.

 

Key Trends: The Shift from Shell Companies to Stablecoins

Cryptocurrency networks experienced a sharp spike in money laundering in 2025, which was prompted by intensified sanctions evasion through nation-state adoption of crypto rails, rapid growth of ruble-pegged stablecoins like A7A5, expansion of Chinese-language escrow and underground banking networks and improved blockchain attribution tools that uncovered previously hidden transactions.

 

Venezuela Oil

Venezuela’s state-owned oil company, PDVSA, has used USDT (Tether) to settle crude‑oil transactions through shadow fleets and over-the-counter (OTC) brokers, enabling continued exports to buyers such as China despite sanctions. This practice has been documented as part of a broader strategy to route oil‑derived revenue through crypto rails rather than the formal banking system.⁶

 

Chinese Money Laundering Networks

The operation of Chinese Money Laundering Networks (CMLNs) demonstrates the global scale of modern financial crime, processing over $16.1 billion in illicit cryptocurrency funds in 2025 by using stablecoins as a settlement layer for underground banking systems. This figure represents approximately 20% of global crypto money laundering activity for the year, highlighting the networks' dominance in scam facilitation, sanctions evasion and other illicit activities through Telegram-based marketplaces, OTC brokers and multilayered wallet structures.⁷

 

Russian A7A5

The Russia-linked stablecoin A7A5, a ruble-pegged stablecoin, processed over $100 billion in transactions in its first year. A7A5 allows Russian entities to bypass Western banking by swapping rubles for globally liquid USDT on decentralized exchanges.⁸ These groups effectively used technology to exploit fragmented global oversight.

 

Iran Crypto Links Exposed

Major investigations by The New York Times and The Wall Street Journal revealed that, between 2024 and 2025, Binance facilitated approximately $1 billion (WSJ) to $1.7 billion (NYT) in transfers to Iranian-linked entities, including the Islamic Revolutionary Guard Corps and Houthi movement. These transactions primarily used USDT on the Tron blockchain to exploit high liquidity and pseudonymity. The controversy escalated after Binance reportedly fired senior investigators who flagged these breaches, triggering a formal U.S. Senate inquiry into potential violations of the exchange’s federal monitorship agreement.^9,10

 

Hamas Fundraising

U.S. authorities disrupted a major terrorist financing campaign in 2025 involving digital assets linked to Hamas, highlighting how extremist networks increasingly exploit crypto for fundraising and obfuscation.¹¹

 

Hybrid Models: The New Normal

While traditional methods like shell companies and trade-based schemes remain active and under mature enforcement, illicit actors are pivoting toward a "mixed" financing model that integrates digital technologies with conventional techniques to exploit lighter oversight.

According to the Financial Action Task Force (FATF), terrorist financing has become highly decentralized, shifting toward regional hubs and self-financed cells that use a diverse range of funding sources, from legitimate business investments to criminal proceeds. This evolution is increasingly marked by "technology-enabled microfinancing," where lone actors, often younger individuals, use gaming platforms and social media features to fund activities. Furthermore, a growing convergence between organized crime and terrorist networks—combined with the low visibility of micro-transactions in racially or politically motivated attacks—has created a complex landscape that traditional, top-down monitoring struggles to penetrate.

 

Record Drop in AML Enforcement: Led by Sharp U.S. Decline

Regulators worldwide saw a marked decline in AML enforcement in 2025, reflecting shifts in regional priorities. Global penalties for AML/ countering the financing of terrorism (CFT), sanctions and customer due diligence violations totaled $3.8 billion in 2025, an 18% drop from $4.6 billion in 2024 and continuing a downward trend from $6.6 billion in 2023. The U.S. levied approximately $1.7 billion in penalties, marking a 61% decline from the previous year, as enforcement focus shifted toward EMEA and APAC regions, where fines rose sharply by 767% and 44%, respectively.^12,13 The U.S. penalty reduction underscores a more restrained approach amid regulatory staff cuts and a government shutdown, potentially signaling increased risks for illicit finance.

 

Crypto Exchanges in the Crosshairs

The cryptocurrency sector faced the heaviest enforcement in 2025, with over $1 billion in fines globally, including major actions against exchanges for inadequate AML and know your customer (KYC) programs. Notable U.S. cases included a $297 million penalty against PEKEN Global Limited (KuCoin) for failing to implement effective AML measures and report suspicious transactions, a $100 million fine on BitMEX for willful AML program deficiencies, and a $500 million guilty plea by OKX for operating an unlicensed money transmitting business without registering with the Financial Crimes Enforcement Network (FinCEN).¹⁴

 

Banks Get a Pass — For Now

These cases illustrate a clear pivot toward emerging technology sectors in enforcement. Notably, throughout 2025, not one U.S. bank faced a major AML, CFT, or sanctions penalty, a first in over 20 years.¹⁵ The overall drop in fines, reversing prior increases, raises concerns that weakened enforcement may embolden illicit actors, emphasizing the need for renewed vigilance and resource allocation.

The enforcement lull, however, comes with a warning: complacency could prove costly as threats continue to evolve. According to Tom Bock, U.S. Head of Financial Crime Advisory at Kroll, “While 2025 marked the first year in more than two decades without a major AML or sanctions penalty for a U.S. bank, this decline in enforcement should not be misread as a signal to ease up. To stay ahead of evolving threats, banks must continue investing in the strength of their financial crime programs and the technology that underpins them.”

 

Key Drivers Fueling the Surge in Illicit Finance

Multiple factors explain the recent acceleration in money laundering and terrorist financing:

• Cryptocurrency and Decentralized Finance: The rapid adoption of cryptocurrency has opened new avenues for criminals. Decentralized finance (DeFi) platforms, cryptocurrency mixers and privacy coins allow bad actors to obscure transaction trails, making it harder for investigators to follow the money. Blockchain transactions are traceable but can be laundered through complex methods, such as chain hopping and tumblers, that challenge legacy AML systems. Crypto-laundering volumes skyrocketed in 2025 as criminals exploited these features, drawn by the promise of speed and global reach. Moreover, the high velocity and intricate layering of these transactions further hinder real-time detection by traditional monitoring tools.

• Domestic Fragmentation: While traditional banks undergo frequent, in-depth scrutiny by federal regulators like the FDIC and OCC, non-bank intermediaries like crypto exchanges, handling trillions in transactions annually, are primarily regulated at the state level through money transmitter licenses, such as New York's BitLicense or equivalent requirements in other states. Federal oversight from agencies like FinCEN mandates AML compliance as money services businesses but often involves rarer, less rigorous examinations amid ongoing jurisdictional debates. This fragmented, state-heavy system creates exploitable loopholes for sophisticated laundering networks.

The lack of comprehensive regulation is exemplified by the Digital Asset Market CLARITY Act, which passed the U.S. House in July 2025 but remains stalled in the Senate as of early 2026, delaying much-needed clarity on jurisdiction between the SEC and Commodity Futures Trading Commission (CFTC) over digital assets. This regulatory limbo extends to other sectors, including the absence of AML requirements for U.S. registered investment advisers (RIAs) and exempt reporting advisers, where a final rule issued in 2024 was postponed multiple times, with the effective date now delayed until January 1, 2028, allowing high-net-worth and private fund channels to remain vulnerable to illicit flows.

• International Fragmentation: Globally, the lack of alignment on crypto regulations further exacerbates these issues, with uneven implementation of frameworks like the EU's Markets in Crypto-Assets Regulation (MiCA) and persistent gaps in standards, as highlighted by the FATF and Financial Stability Board (FSB), enabling jurisdiction-shopping by criminals and hindering cross-border cooperation despite progress in individual jurisdictions.^16,17 This uneven regulatory landscape allows criminals to route illicit funds through perceived "softer" sectors, exacerbating surges in dirty money flows.Terrorist financing remains a persistent threat. While difficult to quantify, evidence shows terrorists are blending conventional methods with digital tools to evade detection. The FATF found nearly 70% of jurisdictions globally still struggle to effectively disrupt terrorist financing networks, creating cross-border vulnerabilities that impact security.¹⁸ Estimates suggest that the majority of large laundering schemes cross at least one jurisdictional border, capitalizing on weak points in the global regulatory mosaic.

As a result, this patchwork oversight, often described as a weakening, "loosely knitted-together safety net," has encouraged criminals to exploit jurisdictions and sectors with reduced scrutiny. Scandals like the one involving the Huione Group, a Cambodia-based financial conglomerate with ties to the ruling Hun family, exemplify this dynamic. Implicated in laundering over $4 billion in illicit proceeds from cyber scams, pig butchering frauds and North Korean hacks between 2021 and 2025, Huione and its subsidiary Huione Pay routed flagged funds to major exchanges including Binance and OKX.

• U.S. Enforcement Erosion: Deregulation trends under the recent U.S. administration have further signaled a more permissive environment for illicit actors, compounding oversight gaps. High-profile decisions include the Trump administration's actions in early 2025, such as disbanding a Justice Department unit dedicated to investigating crypto-related crimes in April, dropping enforcement actions against over a dozen cryptocurrency firms and issuing pardons to several crypto executives convicted of AML violations.^19,20 
  The IRS office overseeing AML compliance at nonbank financial institutions, including crypto firms classified as money service businesses, saw its staff drop 33% to 139 agents in 2025, the lowest since 2017, despite sector growth in scale, volume, and complexity.²¹ This erosion leaves more potential AML violations undetected, heightening risks to market integrity and national security as enforcement resources fail to match evolving financial technologies.

 

Fighting Back: Solutions and Tech Innovations

Amid surging illicit finance, policymakers and industry leaders are advocating for enhanced AML/CFT measures. Key solutions include:

• Closing Regulatory Gaps: Governments are moving to expand and clarify AML coverage. The U.S. House passed the Digital Asset Market CLARITY Act in July 2025 to clarify regulatory frameworks for cryptocurrencies and stablecoins, assigning oversight roles to the SEC and CFTC, setting standards for exchanges and applying Bank Secrecy Act obligations to digital asset firms. This aims to harmonize rules and seal loopholes. Similarly, the EU launched the Anti-Money Laundering Authority (AMLA) in 2025 to supervise high-risk cross-border entities and enforce uniform standards across member states. These initiatives exemplify a broader international effort, driven by bodies like the FATF, to harmonize AML/CFT regulations and extend oversight to previously exempt sectors, such as investment advisers (with U.S. FinCEN rules delayed until 2028) and real estate (with U.S. reporting requirements effective March 2026), thereby deterring criminals from abusing regulatory gaps in the financial system.

• Leveraging Technology – AI and Blockchain Analytics: Financial institutions and regulators are investing heavily in advanced tools to counter illicit finance. Blockchain analytics firms like Chainalysis and TRM Labs enable tracking of crypto transactions across wallets and chains, identifying suspicious patterns and linking them to real-world entities. TRM's 2025 Beacon Network facilitates real-time sharing of flagged wallet addresses among exchanges and law enforcement, speeding up freezes of illicit funds. AI and machine learning are revolutionizing AML compliance via transaction monitoring systems that analyze vast data for anomalies overlooked by rule-based approaches. Recent surveys reveal near-universal AI adoption in AML workflows, with 94% of organizations planning to maintain or expand integration for enhanced detection efficiency and reduced false positives.²² As Mr. Stipano aptly observes, “Technology is a double-edged sword: while it is a powerful tool to fight financial crime, it also creates opportunities that are being exploited by illicit actors.”

Real-world deployments demonstrate measurable impact. Case studies, such as those from HSBC and JPMorgan Chase, show AI slashing alert noise and uncovering novel laundering typologies. By leveraging machine learning algorithms to analyze customer data and identify risk, JPMorgan Chase reduced false positives by 95% while enhancing the overall accuracy of its AML program.²³ Similarly, HSBC achieved a 60% reduction in false alerts and a fourfold increase in identified financial crime by implementing a dynamic risk assessment platform that prioritizes high-value threats over traditional rule-based alerts.²⁴

• Public-Private and International Cooperation: The transnational nature of criminal finance demands collaborative efforts. Regulators and industry participants are enhancing information-sharing frameworks to eliminate silos.. Key initiatives include the U.S. FinCEN Exchange, which facilitates voluntary public-private dialogues on priority illicit finance threats such as money laundering and terrorist financing, and the Egmont Group, enabling secure intelligence exchanges among global financial intelligence units to combat emerging fraud and terror-financing schemes. These mechanisms ensure red flags identified in one jurisdiction prompt preventive actions elsewhere. Cross-border cooperation is essential for countering terrorist financing, as the FATF urges tight public-private coordination to address vulnerabilities in the global system.

• Resource and Training Boost: With IRS staffing at multiyear lows and enforcement resources stretched thin, the private sector must shoulder a greater share of compliance investment. Banks are committing more resources KPMG’s 2025 Banking Survey found 88% prioritizing investments in regulatory compliance and risk management over the next 12 months.²⁵ These efforts, paired with training and AI technology investments, can bolster defenses against evolving laundering techniques.

 

Programmable AML: Tomorrow’s Safeguards on the Horizon

The persistent evolution of money laundering and terrorist financing through 2025 and 2026 underscores a reality where illicit finance rapidly adapts to exploit systemic gaps. While regulatory harmonization and advanced AI offer a framework for containment, the transition toward a secure digital economy depends on bridging the “provenance gap”: the inability to verify the origin of funds in real time. This could be achieved through embedded compliance, in which AML protocols and KYC standards are integrated directly into blockchain logic and smart contracts. By automating AML/KYC policy enforcement and ensuring cross-border legal finality, these "programmable" systems could potentially allow for real-time intervention without the manual lag. Ultimately, sustained regulatory vigilance, innovative compliance technologies and deeper international cooperation will be essential for the financial system to stay ahead of increasingly sophisticated illicit actors.

If you’d like to explore this topic further or discuss how Kroll can help you stay ahead of regulatory changes, get in touch with our team today.

 

Sources
¹TRM Labs. (2026, January 28). TRM’s new crypto crime report shows illicit flows hit a record USD 158 B in 2025. TRM Labs. Retrieved March 1, 2026, from https://www.trmlabs.com/resources/blog/trms-new-crypto-crime-report-shows-illicit-flows-hit-a-record-usd-158b-in-2025
²United Nations Office on Drugs and Crime. (n.d.). Money laundering overview. https://www.unodc.org/unodc/en/money-laundering/overview.html
³Napier AI. (2025, October 21). Money laundering costs $5.5 trillion USD across the globe, Napier AI finds. https://www.napier.ai/post/ai-aml-index-2025-2026
⁴TRM Labs. (2026, January 28). TRM’s new crypto crime report shows illicit flows hit a record USD 158 B in 2025. TRM Labs. Retrieved March 1, 2026, from https://www.trmlabs.com/resources/blog/trms-new-crypto-crime-report-shows-illicit-flows-hit-a-record-usd-158b-in-2025
⁵Napier AI. (2025, October 21). Money laundering costs $5.5 trillion USD across the globe, Napier AI finds: AI/AML Index 2025–2026. https://www.napier.ai/post/ai-aml-index-2025-2026
⁶AINVEST. (2025). How cryptocurrencies became tools for sanctions evasion: The role of Tether in Venezuela’s oil sector. https://www.ainvest.com/news/cryptocurrencies-tools-sanctions-evasion-tether-role-venezuela-oil-sector-2601/
⁷Chainalysis Team. (2026, January 27). Chinese language money laundering networks emerge as major facilitators of the illicit crypto economy, now driving 20% of laundering activity. Chainalysis. https://www.chainalysis.com/blog/2026-crypto-money-laundering
⁸Ambaye, M. (2026, January 22). Russia-tied stablecoin A7A5 tops $100 billion in transactions despite sanctions. Bloomberg. https://www.bloomberg.com/news/articles/2026-01-22/russia-tied-stablecoin-a7a5-tops-100-billion-in-transactions-despite-sanctions
⁹The New York Times: "Binance Employees Find $1.7 Billion in Crypto Was Sent to Iranian Entities" - https://www.nytimes.com/2026/02/23/technology/binance-employees-iran-firings.html
¹⁰The Wall Street Journal: "Binance Fired Staff Who Flagged $1 Billion Moving to Sanctioned Iran Entities" - https://www.wsj.com/finance/currencies/binance-iran-sanctions-financing-staff-b1648133
¹¹U.S. Department of Justice, Office of Public Affairs. (2025, March 27). Justice Department disrupts Hamas terrorist financing scheme through seizure of cryptocurrency. https://www.justice.gov/opa/pr/justice-department-disrupts-hamas-terrorist-financing-scheme-through-seizure-cryptocurrency
¹²Corporate Compliance Insights. (2026, January 15). Regulatory penalties dropped in ’25, led by sharp US decline. https://www.corporatecomplianceinsights.com/news-roundup-january-15-2026/
¹³Fenergo. (2025). Global financial regulatory penalties fall by 18% in 2025 as enforcement shifts from US to EMEA and APAC. https://resources.fenergo.com/newsroom/global-financial-regulatory-penalties-fall-by-18-in-2025-as-enforcement-shifts-from-us-to-emea-and-apac
¹⁴Institute for Financial Integrity. (2025, December 9). AML/CFT and sanctions enforcement actions in 2025: A historic year for banks and state regulators. https://finintegrity.org/aml-cft-and-sanctions-enforcement-actions-in-2025/
¹⁵Institute for Financial Integrity. (2025, December 9). AML/CFT and sanctions enforcement actions in 2025: A historic year for banks and state regulators. https://finintegrity.org/aml-cft-and-sanctions-enforcement-actions-in-2025/
¹⁶Financial Stability Board. (2025, October). FSB finds significant gaps and inconsistencies in implementation of crypto and stablecoin recommendations. https://www.fsb.org/2025/10/fsb-finds-significant-gaps-and-inconsistencies-in-implementation-of-crypto-and-stablecoin-recommendations/
¹⁷Financial Action Task Force. (2025, June 26). Targeted update on the implementation of the FATF Standards on virtual assets and VASPs. https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html
¹⁸Financial Action Task Force. (2025, July). Comprehensive update on terrorist financing risks. https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html
¹⁹DOJ Memorandum: DAG Todd Blanche, "Ending Regulation By Prosecution", April 7, 2025. Available at: https://www.justice.gov/dag/media/1395781/dl?inline
²⁰Nelson, J. (2026, January 1). All of Trump’s pardons of prominent crypto figures—so far. Yahoo Finance. https://finance.yahoo.com/news/trump-pardons-prominent-crypto-figures-140103039.html?guccounter=1
²¹International Consortium of Investigative Journalists. (2026, February 17). As crypto industry expands, U.S. slashes office examining dirty money safeguards of cryptocurrency exchanges. ICIJ.net. https://www.icij.org/investigations/coin-laundry/as-crypto-industry-expands-u-s-slashes-office-examining-dirty-money-safeguards-of-cryptocurrency-exchanges/
²²SEON. (2026). 2026 Fraud & AML Leaders Report: AI Reality Check. https://seon.io/landing/2026-fraud-and-aml-leaders-report
²³AI.Business. (2024, March 26). 95% fewer false alarms: JPMorgan Chase uses AI to sharpen anti-money laundering efforts. https://ai.business/2024/05/15/95-fewer-false-alarms-jpmorgan-chase-uses-ai-to-sharpen-anti-money-laundering-efforts/
²⁴Chief AI Officer. (2025, September 2). How HSBC's AI catches 4x more financial criminals while cutting false alarms by 60%. https://www.chiefaiofficer.com/how-hsbcs-ai-catches-4x-more-financial-criminals-while-cutting-false-alarms-by-60/
²⁵KPMG LLP. (2025). 2025 banking survey: Technology. https://kpmg.com/kpmg-us/content/dam/kpmg/pdf/gated/2025/kpmg-banking-survey.pdf