AML Trends 2025: Old Typologies Reborn, New Risks Emerging

The latest Tracfin report on the state of the threat for 2024–2025 marks a decisive shift in the fight against money laundering, underlining how older laundering methods are resurfacing in more complex forms while new vulnerabilities are born out of technological disruption. Financial intelligence units, regulators, and compliance officers are increasingly confronted with a dual reality: laundering through traditional channels such as real estate or trade transactions now unfolds in parallel with digital risks tied to cryptoassets, decentralized finance, and hidden cross-border movements. What we are witnessing in the emerging AML trends of 2025 are not fragmented signals but interconnected risks, where organized crime, tax fraud, and digital innovation converge to create layered threats.

The year 2025 is defined by a growing sophistication of laundering mechanisms, a blurring of the line between legitimate and illicit flows, and a sense of shared responsibility extending across both financial and non-financial sectors. Examining this landscape through the lens of fraud, digital assets, real estate, organized crime, and institutional responses reveals just how deep these shifts run.

Among the most striking developments is the normalization of cryptoassets as laundering tools. What had previously been seen as an emerging phenomenon has now become an entrenched risk. Fraudulent investment operations involving tokens and NFTs, rug pulls orchestrated within decentralized finance, and cross-border transfers carried out via stablecoins can no longer be regarded as marginal practices. These dynamics demonstrate how blockchain-based assets have become multipurpose instruments for criminals, enabling everything from conventional laundering to sanction evasion.

The report draws attention to the exploitation of influencers in online promotions of questionable tokens, which regularly result in sudden inflows of investor money followed by the disappearance of project organizers. The growing use of peer-to-peer exchanges and non-custodial wallets further complicates detection, since transactions bypass regulated intermediaries. Criminals now frequently merge virtual assets with traditional laundering methods: for instance, narcotics proceeds can be converted into Bitcoin and then reintegrated into the financial system through real estate purchases or luxury acquisitions. The convergence of digital channels and conventional laundering calls for what experts describe as a dual-layer detection framework—one that monitors on-chain activity while also reinforcing traditional KYC models.

While regulatory frameworks are advancing, loopholes remain. Prestataires de services sur actifs numériques are subject to obligations, but cross-border arbitrage allows offenders to operate in jurisdictions with weaker controls. For institutions, the immediate priorities are strengthening blockchain analytics, identifying behavioral red flags among clients, and tightening oversight of payment institutions linked to crypto operations.

Parallel to these developments, real estate and private wealth management continue to be exploited as laundering vehicles. Tracfin highlights multiple cases where individuals manipulate asset valuations in their wealth declarations to evade tax liabilities. High-net-worth individuals and politically exposed persons remain particularly risky when they structure ownership through sociétés civiles immobilières or offshore entities.

Fraud targeting the Impôt sur la fortune immobilière has become emblematic: taxpayers declare properties at artificially deflated values to reduce taxable exposure, only to leverage the very same properties for financing purposes at significantly higher declared valuations. This discrepancy clearly signals an intent to conceal and exposes a laundering vulnerability. Similarly, dividend fraud through foreign holding companies enables tax evasion while simultaneously funneling funds into luxury properties across Europe. Real estate remains attractive not only because of its capacity to absorb large sums of capital but also due to its potential for creating intricate ownership layers that obscure beneficial ownership. Compliance professionals must therefore sharpen their focus on valuations, financing mechanisms, and the links between offshore entities and domestic acquisitions. The overlap between fiscal fraud and laundering underscores the necessity of collaboration between financial institutions, notaries, accountants, and regulatory bodies.

Organized crime groups continue to dominate laundering streams across Europe, with drug trafficking remaining central. According to Tracfin, narcotics proceeds feed into complex layering strategies that involve manual money changers, front companies in the construction sector, and cross-border shell entities. Increasingly, these networks deploy hybrid models that combine cash-heavy businesses, electronic money, and cryptoassets.

Another notable phenomenon is the misuse of tax credits such as service à la personne reductions or charitable donations, which can lend an air of legitimacy to illicit funds. Fraudulent exploitation of chèques cadeaux and other electronic instruments illustrates how even small-value exemptions can, when scaled systematically, generate major laundering threats. These practices not only channel illicit proceeds but also corrode public trust in tax systems.

Trade-based money laundering also remains a preferred channel, as manipulated invoices, falsified shipping documentation, and cross-border intermediaries mask the real origins of funds. The ability of Tracfin to block suspicious transfers under Article L.561-24 of the Code monétaire et financier reflects how financial intelligence is shifting toward active disruption. Yet the sheer magnitude of proceeds tied to organized crime means that more predictive analytics and broader European cooperation are urgently required.

The evolution of AML trends in 2025 makes clear that vigilance can no longer be restricted to banks and major financial players. Under French law, more than 50 professions are designated as declarants, from lawyers to real estate agents and accountants. Their vigilance, combined with the analytical capabilities of FIUs, forms a crucial public-private partnership in mitigating risks. Institutional gatherings such as Tracfin’s annual meetings reinforce the message that every sector must stay engaged. Fraud involving public subsidies, laundering through luxury markets, and the financing of extremism via online platforms demonstrate the widening scope of AML. The new law of June 2025 targeting narcotrafficking confirms a more forceful legislative environment, one deliberately modeled to mirror anti-terrorism frameworks in its severity.

The overarching challenge is adaptability. Criminal networks innovate faster than regulatory systems, and without sustained investment in training, technology, and intelligence-sharing, compliance structures risk being reactive rather than forward-looking. Effective LCB-FT enforcement is not the responsibility of financial actors alone but a collective duty shared by regulators, law enforcement, and civil society at large.

What emerges from the analysis of AML trends in 2025 is a paradox. On one side, institutions are better equipped than ever with advanced detection tools, enhanced intelligence capacities, and more robust regulatory frameworks. On the other, criminals adapt continuously, exploiting weaknesses in both digital and traditional systems. Manipulation of real estate, fraud in crypto markets, trade-based laundering, and misuse of tax incentives reveal how vulnerabilities span every layer of the economy.

The way forward lies in convergence: integrating on-chain analytics with off-chain monitoring, fusing fiscal data into AML assessments, and incentivizing proactive identification of large-scale criminal networks. The success of AML efforts will hinge not solely on compliance but on innovation, cooperation, and accountability. As the Tracfin report makes clear, “each euro recovered is not just a victory against fraud but a reinforcement of public trust.” Entering deeper into 2025, the central question for compliance professionals is no longer whether risks will intensify, but whether frameworks can adapt quickly enough to prevent systemic erosion.

By fLEXI tEAM