3 Financial Crime Risks to Watch in 2026

What senior management and compliance leaders should prepare for now

As we step into 2026, compliance teams are carrying more weight than ever.

The pressure is real: evolving threats, changing regulatory expectations, limited resources, and rising demands from both regulators and leadership. For many organisations, staying ahead can feel like building the plane while flying it.

Below are three financial crime risks leadership teams should understand in 2026, along with practical areas to strengthen.

Risk 1: Money laundering

Money laundering is becoming harder to spot because it does not always look suspicious. Criminals increasingly use real companies, real invoices, and real-looking transactions to make illegally-derived funds appear legitimate.

This means a customer can look fully legitimate on paper, while the activity patterns tell a different story.

Why this matters

If the organisation cannot clearly explain why a customer’s activity makes commercial sense, it increases the risk of:

• onboarding higher-risk activity without realising it,

• missing red flags until the issue becomes serious,

• struggling to justify decisions to regulators after the fact.

  
  

Where to focus

Treat complex corporate structures as a risk signal: Complex ownership is not automatically a problem, but it should trigger questions. Examples include complex structures of companies, frequent changes in ownership, and anything that doesn’t match the business purpose.

Understand how the company operates, not only who owns it: Senior management does not need to review files, but you should expect the business to be able to explain:

• what their customer sells,

• who it sells to,

• where funds come from and where they go,

• what “normal” activity looks like for this customer.

Apply closer scrutiny to high-volume cross-border flows: Large or frequent international payments are in most cases legitimate. But due to their complexity, they are also attractive to actors that are lookging to hide illegal money flows - especially when multiple countries and intermediaries are involved.

A useful question to ask internally: If a regulator asked tomorrow “why does the customer activity make sense?”, could we answer clearly?

Risk 2: Fraud

Fraud remains one of the most immediate and costly risks. APP scams, fake investments, account takeovers, and cyber-enabled fraud continue to cause heavy losses. These incidents affect customers directly, create operational disruption, and often lead to complaints and escalation.

Why this matters

Fraud is not only a “front-line” issue. It can create:

• financial losses that are difficult to recover,

• reputational damage and customer churn,

• operational strain from manual reviews and incident response,

• regulatory attention if the organisation appears unprepared.

Where to focus

Ensure fraud risk assessments reflect current methods: Fraud evolves fast. Your fraud risk assessment should be updated based on what is happening now - not what was common last year.

Strengthen coordination across fraud, AML, tech, and productA common weakness is poor coordination. Criminals exploit gaps between teams. Leadership should push for shared ownership and shared visibility.

Define ownership across prevention, detection, and response:

• Prevention: reducing the chance of loss before it happens

• Detection: identifying suspicious activity quickly

• Response: acting fast when something goes wrong (containment, investigation, reporting, customer support)

A useful question to ask internally: If fraud incidents doubled next month, do we have a clear response plan and assigned owners - or would we end up reacting case by case under pressure?

Risk 3: Sanctions evasion

Sanctions evasion is no longer limited to simple attempts to bypass name screening. It increasingly involves intermediaries, layered transaction chains, indirect routes, and trade-based methods that make restricted activity harder to detect.

Why this matters

Sanctions breaches can result in severe outcomes:

• regulatory action,

• damage to banking relationships,

• restrictions on business operations,

• long-term reputational impact.

Importantly, “no screening hit” does not always mean “no sanctions risk.”

Where to focus

Do due diligence across the full transaction chain when risk indicators appear: Sometimes the risk is not the immediate customer, but the wider network: counterparties, beneficiaries, goods, routes, or end-users.

Escalate when the economic rationale is unclear: When a transaction does not make commercial sense, staff should feel supported to pause and escalate to the relevant person as per your internal process. This is a governance issue as much as a compliance issue.

Review trade activity based on substance, not only paperwork: Documents can look complete while the underlying activity is still high risk. Reviews should test plausibility: goods, pricing, routes, and counterparties.

A useful question to ask internally: Are we relying only on screening tools, or are we also challenging activity that doesn’t make commercial sense?

Financial Crime Risks 2026: Leadership Priorities

2026 will demand anti-financial crime programs that are practical, coordinated, and defensible under scrutiny.

The objective is not to eliminate all risk. The objective is to build control:

• clear ownership,

• strong coordination across teams,

• evidence-based decisions that hold up when challenged.

A strong program protects the institution, the team, and the customers you serve.

Most regulated firms do not need more theory. They need clarity on what matters for their specific business model, and a practical way to turn risk into controls that actually work day-to-day.

In 2026, the most valuable compliance work will be the work that brings structure: clear priorities, aligned teams, and controls that protect customers while remaining operationally realistic.

That is how you stay in control as expectations rise, and how you avoid having to rebuild under pressure.