• Sep 17, 2025
  • < 1 min read

Ask Sumsubers: What new or unexpected methods of money laundering are you seeing emerge?

It’s no longer true that only financial companies are vulnerable to money laundering. Criminals now exploit a wide range of industries—from sports and art to real estate and crypto—to move illicit funds under the radar.

Sumsub keeps getting questions from our followers about the specifics of regulatory compliance, verification, automated solutions, and everything in between. We’ve therefore decided to launch a monthly Q&A series, where our legal, tech, and other experts answer your most frequently asked questions. Check out The Sumsuber and our social media for new answers, and don’t forget to ask about the things that interest you. 

This week’s focus is on money laundering schemes and AML compliance. Arina Runiantseva, Lead Legal Counsel for Europe & MEA at Sumsub, will discuss both emerging and persistent money laundering schemes, as well as the counter-measures needed to stay compliant.

It’s no longer true that only financial companies are vulnerable to money laundering. Criminals now exploit a wide range of industries—from sports and art to real estate and crypto—to move illicit funds under the radar.

Money laundering (ML) schemes are usually based on the same core stages: placement, layering, and integration, but the methods used to execute these stages are constantly evolving. Oftentimes criminals are among the first to tackle the latest technological developments and regulatory blind spots. Traditional channels—like real estate, trade, and cash-intensive businesses—still remain attractive and “popular,” of course. But new tactics are emerging, and they blend digital innovation with old laundering tricks. Let’s see a few:

1. Artificial Intelligence (AI). AI today is, unfortunately, used for both good and bad. AI can be a great facilitator of money laundering, as it’s often used to create synthetic identities, deepfakes, and forged documents that bypass traditional KYC checks—all used to hide criminals’ true identities, move illicit funds undetected, and avoid linking their activities to money laundering or other crimes. AI also helps criminals automate transactions, obscure patterns, and exploit platforms like DeFi and gaming for anonymity at scale.

But the good news is that AI can also help spot criminal activity by detecting anomalies, identifying synthetic identities and deepfakes, and uncovering hidden laundering patterns across vast datasets using advanced tools like liveness detection, behavioral analytics, and transaction monitoring.

2. Cryptocurrencies as high-priority AML risks. Cryptocurrencies have long been recognized as a high-risk domain from a money laundering perspective. Although regulations affecting crypto keep tightening worldwide and frameworks clarified, this sector remains highly vulnerable. With the rise of decentralized finance (DeFi), criminals are using decentralized exchanges (DEXs), cross-chain transfers, stablecoins, and privacy-focused cryptocurrencies to obscure transactional trails and evade detection.

The European Union’s new Anti-Money Laundering Authority (AMLA) has reaffirmed this assessment, pointing to persistent challenges, such as transactional anonymity, the speed and borderless nature of transfers, and a fragmented regulatory environment that continues to limit effective oversight.

3. NFTs and digital collectibles. Non-fungible tokens (NFTs) and other digital collectibles have created a new, largely unregulated marketplace where ML can flourish. NFT markets actually mirror many of the risks traditionally associated with art and luxury assets. The subjective valuation of NFTs, anonymity of blockchain transactions and the ease of cross-border transfers make them an appealing channel for layering and obscuring illicit funds. Criminal actors can purchase NFTs with illicit proceeds, artificially inflate their value through wash trading, and then resell them to integrate funds into the legitimate economy. It’s true though that regulatory scrutiny for NFT marketplaces is beginning to increase. Yet, the sector remains highly vulnerable. Enhanced due diligence, transaction monitoring on NFT platforms, and industry-wide transparency measures are therefore critical to mitigating the risks of ML and other crimes.

4. Smaller entities in regulatory blind spots. Strong compliance frameworks in major regulated institutions make it much harder for criminals to launder money. That’s why they prefer to shift their activities to sectors and entities with weaker oversight. Examples are smaller regional casinos with limited AML controls, emerging fintech providers offering cross-border payment solutions, and non-financial businesses, such as real estate agencies, law firms, and luxury goods dealers. These blind spots are increasingly exploited as entry points, which, of course, underscores the need for a holistic, cross-sectoral approach to AML supervision.

5. Money mule networks. Money mules, who serve as intermediaries to move illicit funds through the financial system, are now another great challenge for anti-money laundering efforts. It’s actually one of the most active and disturbing fraud trends today.

The problem of money mules and other criminal networks has grown more pronounced in the digital era, where online banking, instant payments, and global fintech platforms allow criminals to exploit individuals as conduits for laundering. Organized networks now recruit students, gig-economy workers, and vulnerable populations through social media and online job postings, making mule activity easier to scale, faster to execute, and harder to detect—since these recruits often have clean records—unless advanced monitoring and coordinated awareness campaigns are in place.

6. Art and luxury asset laundering. Artworks, antiques, and luxury goods remain attractive vehicles for ML due to their subjective valuations, limited transparency, and ease of transport across jurisdictions. High-value transactions in these markets are an efficient means of layering and integrating illicit funds into the financial system. Add a limited regulatory oversight to this.

So, to sum up, today’s money launderers are adapting their methods by blending traditional typologies with digital innovation. They can use the old vulnerable industries, but in regulatory blind spots and through technological advances available to everyone in 2025. For compliance professionals, the key priorities are strengthening digital identity verification, using blockchain and transaction analytics, extending AML obligations to high-risk non-financial sectors, and addressing displacement risks through coordinated supervision. Ultimately, to fight the evolving and increasingly sophisticated money laundering schemes, AML frameworks must remain adaptive, intelligence-led, and technology-driven.

To help professionals keep pace with evolving threats, we launched Sumsub Academy in April 2025, which offers expert-led courses, hands-on training, and certifications in compliance, risk, and fraud prevention.

The AML Fundamentals course is our latest addition. Launched on September 15, it’s designed to equip professionals with practical skills to fight financial crime. Across six modules and with insights from seven speakers, we cover the foundations of financial crime prevention, transaction monitoring, the risk-based approach, industry-specific AML, and more. Sign up today to join the course and earn your AML certification.

Arina Rumiantseva

Lead Legal Counsel Europe & MEA at Sumsub