2025年亚太地区高管必须了解的四大金融犯罪趋势

© Oliver WymanThe dynamic nature of financial crime (FC) remains a major issue for financial institutions(FIs) in the Asia Pacific region (APAC). This is driven by criminals employing more innovativemethods and advanced technologies to perpetrate crime, and the ever-increasing demandsfrom regulators in the region. In areas where FIs have failed in their anti-money laundering(AML), sanctions, fraud, or compliance obligations, regulators have not been averse toimposing significant enforcementactions.In this complex and changing FC landscape, APAC FIs need to ensure the effectiveness oftheir anti-financial crime (AFC) programs, all while striking the delicate balance betweencustomer experience, effectiveness, and efficiency. In doing so, FIs must continue to keepabreast of evolving and changing regulatory requirements, a shifting geopolitical landscape,and technology advancements including artificial intelligence (AI) and generative AI.HOW REGULATORS ARE RESPONDINGAs FC evolves in complexity, regulations globally continue to evolve in 2025. These changeswill be driven by a continued focus on FIs needing to form a deeper understanding of theircustomers (which includes ultimate beneficial ownership), enhance risk-based approaches,and increasingly adopt advanced AFC risk managementtechnologies.•Strengthening beneficial ownership transparency: A primary focus for regulators,particularly in Southeast Asia, amid the fallout of high-profile money-laundering scandalsin the region. While progress has been made, it is expected that more jurisdictions willestablish or continue to enhance compulsory public registries for beneficialownership.•Enhancing the emphasis on risk-based approaches: Regulators will increasingly requireFIs to adopt and demonstrate an effective risk-based approach to AFC risk management.This will include tailoring their strategies to address specific risks relevant to the FI.In parallel, countries are expected to update their national risk assessment protocolsand embark on a shift from standardized strategies to more flexible, data-driven riskassessments. These will have a downstream implication on how FIs design and managetheir controlframeworks.•Increasing the adoption of advanced AFC risk management technologies: Theapplication of AI must meet regulatory expectations for safety and soundness in thebanking industry and also meet ethical adoption standards. Regulators will increasinglyrequire FIs to not only deploy AI-based models, but also rigorously test and monitorAI models to ensure they do not introduce excessive risks orbiases.•Strengthening international cooperation and data sharing: International cooperationis becoming increasingly vital in the fight against FC as criminal activities and theirproceeds are often transnational in nature. Regulators will continue to prioritizeenhancing global information sharing and cross-border collaboration, which willfacilitate quicker detection and responses to FC that spans multiplecountries. © Oliver WymanTHE CHANGING RISK LANDSCAPE IN 2025As technology continues to evolve, so do the techniques that are employed by criminals.In 2025, various new methods of FC are emerging. These highlight the necessity for FIs tonot only refresh and enhance their risk management programs and the underlying changesin their risk profile, but also demonstrate agility in being able to respond to the dynamicthreatenvironment.SYNTHETIC IDENTITY LAUNDERINGCriminals are increasingly amalgamating genuine and fabricated credentials together toforge new identities. While detecting synthetic identity fraud is challenging, FIs can takesteps to implement effective controls. These include monitoring unusual credit patterns thatcan become obvious upon closer inspection, such as sparse public records, rapid credit build,and the utilization of common addresses. Additionally, advanced fraud detection capabilitiesthat employ deep behavioral analytics can help uncover inconsistencies. FIs need to stayabreast of these technological developments, invest in advanced detection tools, enhancetraining programs, and maintain secure communication channels to protect themselvesand their customers from the significant threats posed bydeepfakes.ONLINE GAMINGCriminals are progressively exploiting online gaming platforms, mainly because ofthe existence of virtual currencies and tradable in-game assets. Players can easilyconvert in-game currencies into real money, enabling the transfer of illicit funds through“money mulling.” Criminals often exploit these platforms to launder their money throughmicrotransactions, which are masked as legitimate purchases of game items or in-gametokens. To address these issues, the FIs engaged in processing payments for theseplatforms as clients or for their individual and entity clients that transact with theseplatforms, need to reassess how they address theserisks.DIGITAL ASSETSDigital assets and cryptocurrencies have become a significant focus for FC regulations.Though t