Money laundering is no longer just about shell companies and anonymous wire transfers; it’s gone high-speed, platform-based and cross-border. Today, criminals exploit instant payments, creator-economy tipping platforms, gaming assets and cross-chain crypto flows in the EU and UK. At the same time, the Council of the European Union’s new Anti-Money Laundering (AML) package extends the list of “obliged entities” to include football clubs, agents and luxury-goods traders while imposing a cash-transaction cap of €10,000.
The Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) in Frankfurt is now operational and is designed to oversee high-risk sectors and crypto-asset service providers. Meanwhile, the Instant Payments Regulation mandates that euro payments clear within ten seconds, intensifying speed-risk for AML and fraud teams. This article will map the new laundering channels, explain how they’re used, and set out what the EU and UK are doing already to stay ahead.
What non-traditional channels are increasingly being used for ML?
Criminals are migrating beyond conventional financial institutions and exploiting newer, less-regulated rails to launder illicit funds. In the digital assets sphere, for example, decentralised finance (DeFi) platforms, cross-chain bridges and on-chain “mixer” services are now favoured for laundering. Bad actors “chain-hop” across networks to break tracing heuristics, then feed tokens into mixers or privacy tools to obscure the origin of funds. Recent analysis from firms such as Elliptic highlights this as a rising typology.
Stablecoins have also emerged as central to illicit flows. Their high liquidity, 24-hour settlement capability and relatively weak intermediary controls make them an attractive corridor. Regulatory bodies such as the Financial Action Task Force (FATF) noted in their 2025 targeted update that stablecoins now play a disproportionate role in crypto-related money laundering.
Beyond crypto, gaming economies and non-fungible token (NFT) markets provide alternative channels. In-game currencies, digital skins and NFT collectables allow value laundering through fragmented oversight. Users can buy high-value game items or NFTs with illicit funds, then resell or transfer them across jurisdictions. Many regulatory commentaries flag this as an emerging risk.
Meanwhile, the creator-economy (micro-donations, streaming tips, subscriptions, etc.) and instant payments/open banking rails enable layering via many small transfers across jurisdictions. Embedded-finance and buy now, pay later (BNPL) wallets likewise present untreated operational gaps, as non-banks or retail brands offer accounts and credit with variable AML controls. Finally, luxury resale platforms (watches, handbags, high-value consignments, etc.) and sectors newly brought into scope, such as professional football clubs or agents, render the integration stage easier. In this way, illicit funds enter legitimate markets disguised as commerce. The evolving regulatory environment means firms must broaden their focus and vigilance well beyond traditional banks.
How and why non-traditional channels are being used?
Criminals are increasingly embracing instant payments and 24/7 crypto settlement to exploit speed and fragmentation in the system. For example, in the European context the European Central Bank (ECB) highlighted that instant payment systems make recovery difficult and detection of suspicious activity challenging due to real-time finality. The logic is simple… funds can be moved, split into many small fragments and re-aggregated or dispersed across jurisdictions before a traditional sanctions check, name screening or behavioural red-flag can react.
Alongside speed comes liquidity and plausible use. Digital assets such as stablecoins, gaming assets or creator payments offer a veneer of legitimacy where someone acquiring in-game tokens or paying influencers might look like normal business. In fact, they are layering illicit funds. Recent Reuters coverage underlines that stablecoins pose the same AML/CTF risks as other assets while providing anonymity or pseudonymity.
Criminal actors also engage in jurisdictional arbitrage by pivoting to weakly supervised venues or pseudo-DeFi models. The FATF notes that uneven implementation of virtual asset service provider (VASP) standards enables cross-border exploitation of the so-called Travel Rule gaps. Further enabling this is the data gap in new verticals, such as luxury resellers, sports intermediaries and embedded finance partners, which often lack mature customer-due-diligence and beneficial-ownership workflows. Regulators in the EU are expanding the scope of obliged entities to tackle this blind spot. Added to this, cross-chain opacity enables bridging and “chain-hopping” where a criminal might move funds via multiple blockchains in small hops to mimic normal user behaviour and frustrate traditional blockchain analytics.
Finally, social engineering at scale is leveraged so that authorised push payment (APP) fraud and money-mule recruitment turn everyday consumers or small and medium enterprises (SMEs) into unwitting conduits. The UK’s reimbursement regime for APP fraud, introduced by the Payment Systems Regulator (PSR), shifted incentives and reinforced the problem space. An additional critical driver is AI, which now accelerates social-engineering, impersonation and mule-recruitment content, as per Europol’s recent warnings.
In short, criminals combine ultra-fast rails, digital asset liquidity, weak jurisdictions, data blind spots and mass social engineering to exploit non-traditional channels for money laundering.
What is already being done to prevent or limit this ML activity?
- Policy & rule-book (EU)
The Council of the European Union and Parliament have adopted a harmonised AML package which sets an EU-wide cap of €10,000 on cash payments, broadens the list of “obliged entities” (including crypto-asset service providers, high-value goods traders, sports clubs) and strengthens beneficial-ownership requirements. At the same time the Transfer of Funds Regulation (TFR) extends traceability requirements to crypto-asset transfers, aiming to bring non-traditional channels into the rule-book.
- Supervision
The newly established European AMLA began operations in July 2025 and is empowered to directly supervise highest-risk cross-border institutions and coordinate national Financial Intelligence Units (FIUs). This strengthens supervision beyond national silos and targets actors who exploit cross-border and non-traditional channels.
- Market controls – Crypto perimeter, UK reforms and payment system controls
Under the Markets in Crypto‑Assets Regulation (MiCA), since 30 December 2024, crypto-asset service providers (CASPs) must be authorised and subject to prudential and conduct requirements. In the UK, the Financial Conduct Authority (FCA) requires any firm marketing crypto assets to UK consumers (including overseas firms) to comply with the financial promotions regime from October 2023. Meanwhile, payment service reforms such as the Payment Systems Regulator’s mandatory reimbursement regime for authorised push payment (APP) scams (effective 7 Oct 2024) compel PSPs to invest in fraud and money-mule detection.
Together, these policy layers, strengthened supervision and targeted market controls aim to shrink the space in which money-laundering via non-traditional channels can operate.
In an era where the perimeter of anti-money-laundering is shifting to cross-chain rails, instant payments and platform economies, the reforms undertaken by the European AMLA, the EU’s AML package and the MiCA Regulation, alongside the UK’s Economic Crime and Corporate Transparency Act (ECCTA) reforms and payments-market controls, have undeniably raised the bar.
Yet the next frontier will hinge on full-scale, real-time, interoperable data linking across platforms and jurisdictions, matching exactly the liquidity flows and latency exploited by criminals. The core takeaway might be follow the liquidity and the latency, that is where the next money-laundering threats will emerge.
And what about you…?
- Where do you see the greatest blind spots in your firm’s current customer-due-diligence or transaction-monitoring frameworks—particularly in emerging, data-light sectors?
- If you had to “follow the liquidity and the latency,” where would you expect the next money-laundering vulnerabilities to appear in your own ecosystem?
