Recent assessments by agencies such as the Financial Crimes Enforcement Network (FinCEN), the Federal Bureau of Investigation (FBI) and the Office of the Director of National Intelligence have highlighted the evolving and complex nature of the fraud threat landscape. Instead of opportunistic scammers, this landscape is increasingly characterized by sophisticated, industrialized criminal enterprises, many of which are also engaged in other serious crimes like terrorism, human trafficking (HT), narcotics importation and cybercrime.

For fraud professionals on the front line, understanding the broader tactics employed by bad actors is paramount. It is not about protecting your organization’s bottom line; it is about aligning with broader national security objectives, including the U.S. administration's focus on state-linked ransomware, fentanyl and the disruption of cartels. In an environment where fraud professionals are concerned about a lack of strategic focus, financial institutions (FIs) can leverage wider national security threats to bolster their counter-fraud activity.

This article highlights the relationship between national security and fraud through the prism of published intelligence assessments and how they can be hot-wired into an FI’s fraud and financial crime functions. Through a process of dissemination, reviews to policies and controls and incorporation into risk management procedures, this intelligence can be at the heart of an informed fraud detection strategy.

Unlike a National Risk Assessment, threat assessments summarize the economic crime threat—based on intelligence—not the inherent or residual risk of criminality across an FI’s footprint. As a result, information is frequently more victim-centric, provides tangible indicators and relates directly to national security priorities.

Fraud has become a key revenue stream for transnational organized crime groups (TOCs) worldwide. Europol’s 2025 “Serious and Organised Crime Threat Assessment”¹ reveals that fraud schemes now rival drug trafficking in profitability across Europe. The U.K.’s National Crime Agency echoes this, noting in its “National Strategic Assessment”² the increasing convergence of fraud, money laundering and cybercrime among domestic and international TOCs. Interpol has highlighted a growing link between fraud and crimes like HT with illicit funds laundered through shell companies, funnel accounts and underground banking.³

TOCs exploit weaknesses in financial systems through social engineering, insider access and intricate money laundering networks. The sheer volume of illicit proceeds generated by these activities necessitates sophisticated mechanisms to obscure their origins and integrate them into the legitimate financial system. This laundering process is a critical enabler of organized fraud, allowing them to reinvest profits, expand operations and evade law enforcement (LE).

TOC-driven fraud schemes include:

• Business email compromise: Criminals use social engineering to manipulate payment instructions, targeting businesses and individuals.⁴
• Investment and romance scams: Often linked to forced labor in Southeast Asia, these schemes (known colloquially as “pig butchering”) combine emotional manipulation with fraudulent investment platforms, frequently using cryptocurrencies. Typologies also include exploitative schemes such as timeshare fraud targeting the elderly.⁵
• Synthetic identity and account takeover fraud: Fraudsters use stolen and fabricated data to create fake identities, open accounts, secure credit or gain unauthorized accesses.⁶

These are not isolated incidents. They are revenue generators fueling broader criminal activities, from fentanyl trafficking to illicit weapons of mass destruction programs—both currently high priorities for the U.S. administration—a link drawn out by a recent threat assessment⁷ highlighting how organized crime and state actors are utilizing cyber-enabled fraud to undermine U.S. interests joining the dots between fraud and wider national security concerns.

The connection between organized crime, fraud, money laundering and geopolitical threats is becoming clearer. The U.S. Department of the Treasury and the United Nations have warned about North Korea’s efforts to use fraud as a tool for sanctions evasion and regime funding, with illicitly obtained funds undergoing sophisticated money laundering techniques—shared by TOCs who use the same professional enablers and even the same crypto wallets.

Recent revelations have spotlighted guarantee platform Huione Group based in Cambodia and designated by FinCEN as a primary money laundering concern.⁸ This designation underscores the critical role certain entities play in facilitating the end-to-end flow of laundered funds derived from various criminal enterprises, including fraud. The Huione Group's activities highlight complex networks and typologies used to obscure the origin of illicit wealth, cross-border transactions and the exploitation of financial vulnerabilities.

Groups linked to the Triads China-based TCO are implicated in global scam operations, money laundering related to fentanyl precursor sales and related illicit financial flows. In addition, the U.S. government's focus on disrupting powerful drug cartels (recently designated as terrorist organizations) means that FIs must be vigilant in detecting and reporting activities that may be linked to these organizations.

Financial tracks left by these cartels, in their need to launder vast sums of money, can often be detected within the mainstream financial system. One of the cartels sanctioned by the U.S. government, the Jalisco New Generation Cartel, is known to undertake timeshare fraud to supplement its revenue streams from its primary narcotic smuggling activity.

U.S. national security priorities concerning China, Iran, cartels and the opioid crisis directly drive financial crime risks, with money laundering being a key component of these activities. The U.S. Department of Justice recently outlined its enforcement priorities which include waste, fraud, abuse, national security, trade, sanctions, cartels and TCOs.⁹ Recent strategic products issued by FinCEN and other U.S. agencies can provide FIs with a sense of focus.

FIs must recognize these linkages. Fraud can expose them to broader geopolitical and national security risks if illicit funds flow unchecked through their systems. The designation of entities like the Huione Group serves as a stark reminder of the scale and complexity of the money laundering threat connected to organized fraud. Recalibrating enhanced due diligence (EDD) on transactions through Cambodia, setting alerts for transactions to unregulated peer-to-peer exchanges or exercising keyword detection for Telegram aliases can help guard against systemic fraud.

To combat the evolving fraud threat and associated money laundering, FIs must move beyond traditional methods. Financial crime controls must be adaptive, intelligence-led and strategically aligned with national security priorities. For U.S. FIs, this includes leveraging areas of focus such as cartel activity and fentanyl trafficking to bolster their defenses against third-party fraud targeting their customers. Key measures include:

• EDD: U.S. FIs should increase scrutiny of transactions involving entities or individuals with known or suspected ties to China-based organized crime such as casinos in the Mekong region. This includes using advanced analytics to detect trade-based money laundering patterns potentially linked to illicit goods or funds between Mexico and China, and strengthening know your customer/EDD for customers engaged in import/export with Chinese counterparties.
• Targeted monitoring: FIs should develop transaction monitoring rules and alerts to identify patterns associated with fentanyl precursors.¹⁰ Collaboration with LE and financial intelligence units (FIUs) to share information on suspected fentanyl-related activity is vital. Robust screening of cryptocurrency wallets sanctioned by LE for cartel or fentanyl trafficking activity is necessary, in addition to screening against relevant sanctions lists. FIs should enhance monitoring of transactions showing indicators of cartel activity, including large cash deposits, funnel accounts and transactions involving front companies.
• Strengthening cybersecurity: Recognize the link between cybercrime and financial fraud, particularly potentially state-sponsored “advanced persistent threat” groups such as the Lazarus Group (itself linked to the Huione Group). FIs must invest in advanced cybersecurity, improve employee training on social engineering and enhance information sharing on emerging cyber-enabled fraud.
• Collaboration: Sharing data and intelligence with LE and FIUs supports investigations into fraud and money laundering. Recent alerts issued by the U.K.’s Joint Money Laundering Intelligence Taskforce and the Office of Financial Sanctions Implementation are intended to highlight strategic gaps and enable FIs to respond according to their risk profile by providing high-quality intelligence to the private sector.¹¹

Leveraging government advisories and threat assessments helps inform risk assessments and compliance programs. Take for instance a recent FBI-issued alert regarding disaster relief scams, undertaken by terrorist groups and nation state actors as a cynical means of expanding their revenue¹²—an example of tackling fraud to inform an effective and reasonably designed anti-money laundering (AML)/counter-terrorist financing program.

Adopting a threat-informed approach that focuses resources on high-risk customers on/offboarding, transactions and geographic areas, while regularly updating risk assessments to reflect evolving threats and national security priorities, is paramount. Tailoring compliance programs to address specific risks associated with sanctioned entities, cartel activity and fentanyl trafficking enables a more effective defense against fraud.

FIs are uniquely positioned in the fight against organized fraud and associated money laundering. They sit at the intersection of criminal proceeds, illicit finance and financial flows. By using insights from strategic threat analysis—like the annual Office of the Director of National Intelligence assessment, FBI alerts or FinCEN advisories—and by strategically aligning with national security priorities—FIs can refine their controls to address real-world threats.

Such an intelligence-led approach requires institutional prioritization. It may mean focusing resources on transaction monitoring related to current geopolitical risks, investing in tools to detect synthetic identities used for fraud, or strengthening controls in regions known for scam operations and the presence of entities involved in illicit marketplaces with a nexus to national security concerns like cartels, fentanyl and cybercrime.

Crucially, institutions must integrate fraud detection into AML risk management. As organized crime increasingly blurs these lines, compliance functions must respond holistically to this complex threat, recognizing that fraud is often a key predicate offense for money laundering, sometimes facilitated by designated entities and strongly influenced by geopolitical rivalries.

The surge in organized fraud and its connection to illicit finance, as underscored by national security analysis, is a fundamental shift in criminal enterprise. FIs that respond with agility and cross-function collaboration, while aligning with national security objectives, not only reduce their own risks but also play a vital role in protecting their customers from fraud and demonstrating a commitment to national security.

For risk assessments to be truly effective they must be intelligence-led, in a program-sensitive fashion allowing resources to be smartly deployed. By aligning threat intelligence, fraud detection technology and by screening against primary money laundering concerns, FIs can navigate the fraud boom with resilience, protecting themselves, their customers and wider national security priorities.

Joby Carpenter, SME, Emerging Threats and Illicit Finance, ACAMS, jcarpenter@acams.org,

1. “Serious and Organised Crime Threat Assessment 2025: The Changing DNA of Serious and Organised Crime,” Europol, 2025, https://www.europol.europa.eu/cms/sites/default/files/documents/EU-SOCTA-2025.pdf
2. “National Strategic Assessment 2025 of Serious and Organised Crime,” National Crime Agency, https://www.nationalcrimeagency.gov.uk/nsa-2025
3. “Interpol Financial Fraud assessment: A global threat boosted by technology,” Interpol, March 11, 2024, https://www.interpol.int/en/News-and-Events/News/2024/INTERPOL-Financial-Fraud-assessment-A-global-threat-boosted-by-technology
4. Public Service Announcement: Business Email Compromise: The $55 Billion Scam,” Federal Bureau of Investigation, September 11, 2024, https://www.ic3.gov/PSA/2024/PSA240911
5. “FinCEN, OFAC, and FBI Joint Notice on Timeshare Fraud Associated with Mexico-Based Transnational Criminal Organizations,” Financial Crimes Enforcement Network, July 16, 2024,  https://www.fincen.gov/news/news-releases/fincen-ofac-and-fbi-joint-notice-timeshare-fraud-associated-mexico-based
6. “Public Service Announcement: Criminals Use Generative Artificial Intelligence to Facilitate Financial Fraud,” Federal Bureau of Investigation, December 3, 2024, https://www.ic3.gov/PSA/2024/PSA241203
7. “Cybercrime: A Multifaceted National Security Threat,” Google Cloud, February 11, 2025, https://cloud.google.com/blog/topics/threat-intelligence/cybercrime-multifaceted-national-security-threat
8. “FinCEN Finds Cambodia-Based Huione Group to be of Primary Money Laundering Concern, Proposes a Rule to Combat Cyber Scams and Heists,” Financial Crimes Enforcement Network, May 1, 2025, https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern
9. “Memorandum: Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” U.S. Department of Justice, May 12, 2025, https://www.justice.gov/opa/media/1400141/dl?inline
10. “Financial Trend Analysis—Fentanyl-Related Illicit Finance: 2024 Threat Pattern & Trend Information,” Financial Crimes Enforcement Network, April 2025, https://www.fincen.gov/sites/default/files/shared/FinCEN-FTA-Fentanyl.pdf
11. “Financial Services Threat Assessment,” Office of Financial Sanctions Implementation HM Treasury, February 2025, https://assets.publishing.service.gov.uk/media/67f3f2467ed82b90fcf5bffc/OFSI_Financial_Services_Threat_Assessment_Report.pdf; “Red Alert—Financial Sanctions Evasion Typologies: Russian Elites and Enablers,” National Crime Agency, July 2022, https://www.nationalcrimeagency.gov.uk/who-we-are/publications/605-necc-financial-sanctions-evasion-russian-elites-and-enablers/file
12. “Public Service Announcement: Scammers Solicit Fake Humanitarian Donations,” Federal Bureau of Investigation, October 24, 2023, https://www.ic3.gov/PSA/2023/PSA231024