When asked who should be concerned about economic crime vulnerabilities, Kevin Newe's response (Assistant Director - Head of Illicit Finance Threats at HMRC) was unequivocal: "Everyone." The multifaceted nature of modern threats means no sector or service can consider itself immune. However, certain systems and services present particularly acute vulnerabilities that demand immediate attention.
The UK's recently published national risk assessment highlights the exploitation of non-bank payment service providers - specifically electronic money institutions (EMIs) and electronic money distributors (EMDs) - as a significant and growing vulnerability.
These services have become prevalent across multiple types of criminality due to their convenient consolidation of services. A single platform can offer fiat currency accounts, cryptocurrency accounts, and virtual IBANs, which increase anonymity and privacy for users. The challenge is compounded by nested services, where an apparently compliant EMI regulated by the FCA may harbour a more criminally complicit EMD at the bottom of the chain, facilitating illicit activity whilst appearing legitimate on the surface.
When combined with dark web integration, these vulnerabilities create substantial challenges for law enforcement and regulatory oversight.
Despite the focus on emerging technologies and digital payment methods, cash-based criminality remains a critical vulnerability. As Europol validated last year, cash continues to play a central role in most predicate offences somewhere within the supply chain.
High street businesses- particularly cash-intensive operations such as barbershops and other cash-rich enterprises - remain of significant interest. There's also substantial focus on organised immigration crime, with evidence suggesting much of the associated money laundering occurs through informal value transfer systems, commonly known as Hawala.
The key challenge lies in how physical cash intersects with virtual currencies and new payment methods. Law enforcement retains the ability to have meaningful impact by targeting physical cash activity before it circulates through more opaque financial systems.
Cifas reported a 59% increase in identity fraud filings within their database last year, reaching 118,000 cases in the first six months of this year alone. This represents a growing and evolving risk that organisations can no longer afford to overlook.
Identity fraud vulnerabilities exist at multiple points, including company formation and registration processes where identity verification may be weak. The upcoming changes to Companies House rules on 18th November 2025 under the Economic Crime and Corporate Transparency Act (ECTA) aim to strengthen these particular areas.
Insider fraud represents another critical vulnerability, with Cifas recording a 32% increase in related filings. This threat manifests in two distinct forms:
Pre-employment threats: Individuals attempting to join organisations through false CVs, fabricated employment histories, or fraudulent qualifications - what's been termed "polygamous working" involving multiple concurrent contracts.
Internal threats: Existing employees motivated to manipulate systems or exploit their access privileges for fraudulent purposes.
Combating insider threats requires a multi-layered approach:
Robust vetting and recruitment: Comprehensive pre-employment checks remain the first line of defence, preventing threats from entering the organisation in the first place.
Ongoing monitoring: Regular checks when employees change roles, coupled with strong controls, segregation of duties, and internal audit procedures throughout employment.
Staff wellbeing: Consideration of factors such as cost-of-living pressures and employee motivation helps prevent the conditions that might push otherwise honest employees towards fraudulent activity - addressing the fraud triangle before it forms.
The new Failure to Prevent (FtP) fraud offence mandates whole-organisation fraud risk assessments as part of reasonable procedures. Organisations conducting these assessments are discovering services and vulnerabilities they weren't previously aware of- highlighting the value of systematic evaluation.
For counter fraud professionals, the message is clear: vulnerabilities exist across traditional and emerging systems. Success requires:
The threat landscape spans from cash on the high street to cryptocurrency in the cloud. Effective protection demands vigilance across the entire spectrum.