In the same week as Barclays received a £42 million fine for failure to manage money laundering risks, HM Treasury and the UK Home Office released the 2025 National Risk Assessment of Money Laundering and Terrorist Financing. As well as setting out the key risks facing the UK today, it highlights changes and trends in money laundering and terrorist financing since 2020.
In this blog, we explore some of the trends in money laundering the Assessment discusses, considering how Open Source Intelligence (OSINT) can play a role in response to – and mitigation of – these risks.
What are the key themes and changes since 2020?
Global insecurity and its impact on methodologies
Rising global insecurity is emphasised throughout the assessment. Geopolitical conflicts such as Russia’s invasion of Ukraine, and the subsequent strengthening of sanctions regimes globally, have shifted the risk landscape and in turn influenced how criminals launder funds. In fact, sanctioned actors are now exploiting traditional laundering networks, underlining an increased overlap between money laundering, kleptocracy and sanctions evasion.
OSINT opportunity:
The criminal networks that facilitate money laundering often engage in other criminal activities, which presents an opportunity, as well as a risk: breaking open these networks may enable law enforcement to prevent more crime with each network that is disrupted. Investigations teams from law enforcement and financial institutions can develop an in-depth understanding of these networks by combining data from open sources, such as corporate registries and publicly available social media.
Accelerated technology adoption
Money-laundering risk status for cryptoasset businesses and EMI/ PSPs increased from medium in 2020 to high in 2025. This isn’t surprising: new financial technologies are emerging faster than regulations can keep up, providing criminals with opportunities to work faster, more globally, and with better identity obfuscation.
OSINT opportunity
If criminals are moving online, they are most likely to leave traces there - and law enforcement must be well-equipped to take advantage of these traces. In these cases, traditional intelligence sources such as financial data or privileged information are often unavailable, and they may only offer a partial picture of the flow of funds. Here, as in cyber investigations, OSINT can help investigations teams create a broader intelligence picture by tracing the identities behind usernames, addresses and other identifiers.
Cash risks remain significant
While digital crime is on the rise, cash-based money-laundering remains commonplace – through businesses, money muling, or even the misuse of legitimate channels such as Post Offices. In fact, the cash generated by criminal activity is estimated to be in excess of £12 billion a year. Cash-intensive businesses continue to be central to UK-based laundering, while Money Service Businesses and International Controller Networks (ICNs) play an important role in moving laundered funds abroad.
OSINT opportunity
While cash itself isn’t visible in online data, there are two ways that cash-based money laundering should be investigated using OSINT.
Firstly, laundered cash is likely to enter the banking system at some point: ultimately, the purpose of laundering is to ‘wash’ money so that it is not obviously the proceeds of crime and can be used for other means. Where a business or individual deposits large amounts of cash that are not in keeping with expected transactions, financial institutions can use OSINT to understand more about the client or counterparty involved and check for indicators of money laundering. There are numerous historic cases where relatively simple OSINT-based checks could have helped banks to avoid fines – not least the aforementioned Barclay’s case.
Secondly, the networks behind the flow of funds frequently leave traces online. Investigators should use OSINT to gather evidence around suspected involvement in money laundering. Complex corporate network structures with obscured ownership and unusual patterns of registration at residential addresses can indicate that companies are not as they seem. Similarly, hard-to-explain social media connections and photos of extravagant purchases can be indicators of involvement that, when combined with internal intelligence, provide a clear picture of criminal networks.
OSINT is essential to both understanding and mitigating risk
Criminal methodologies are constantly evolving, and the trends laid out in the National Risk Assessment of Money Laundering and Terrorist Financing are evidence of this. No one method or technique alone is the answer to fighting crime, but OSINT is part of the answer. Criminals operate as networks, and are increasingly conducting activity online and leaving breadcrumb trails, OSINT is a vital tool in understanding these networks and disrupting their activity: via corporate records, social network analysis, dark web groups, username tracing and more.
OSINT is also pivotal in the thematic research required to understand – and prepare law enforcement for – what’s next. Discussions on forums and the dark web, and activity on public social media can all help policymakers to understand the direction of criminal activity and mitigate future risk.
Finally, OSINT is at its most powerful when combined with internal or privileged data to create a fuller intelligence picture. When harnessed and applied correctly, technologies such as AI will make open source data analysis more efficient. The UK’s government, law enforcement and financial institutions must invest and make OSINT part of their counter-economic crime strategy.
