The opinions expressed here are those of the authors. They do not necessarily reflect the views or positions of UK Finance or its members.

As threats grow more interconnected and sophisticated, regulators are shifting focus to stronger governance and proven effectiveness.

At Themis, we’ve identified the top trends that firms should be tracking across the UK’s financial crime landscape this year. Check out our full Horizon Scanning Report here.

1. AI-enabled fraud takes centre stage

Fraud remains one of the UK’s most pervasive financial crime risks. For banks, fintechs and payment firms, fraud now causes the greatest financial, operational and reputational harm, with early indicators suggesting fraud-related losses in 2025 exceeded 2024’s £1bn benchmark. We’ve already seen AI start to reshape this fraud landscape. From hyper-realistic deepfakes to phishing emails generated in seconds and tailored precisely to a company’s structure and tone, AI is industrialising deception: enabling criminals to scale attacks and sharpen targeting in real time.

2. Crime-as-a-service is on the rise

Crime-as-a-service models on the dark web have further industrialised fraud, as well as other financial crimes such as money laundering. Criminals are offering end-to-end toolkits and services to execute attacks at scale. For instance,  a 21-year-old student was arrested in the UK last year for selling phishing kits linked to £100m worth of fraud. This highlights real concerns over this growing crime type. For firms, this means higher attack volumes, shorter response windows and rising pressure to demonstrate adaptive, intelligence-led controls.

3. Geopolitics dominate illicit finance

The UK continues to attract sanctions evasion and foreign corruption networks. Russian-linked activity remains most prevalent, with additional risks from Iran, Belarus, Libya and the DPRK. Given the fast-moving geopolitical situation in these countries, these risks are likely to intensify. Regulators are also increasingly focused on professional enablers - banks, fintechs, lawyers, accountants and corporate service providers - who now face greater regulatory scrutiny. Crypto assets add another layer of vulnerability, with authorities warning of under-reporting and continued targeting by state-linked actors.

4. Organised crime is more networked

Transnational criminal groups increasingly operate like global businesses. Highly networked “super cartels” combine fraud, money laundering and trafficking crimes across borders. These groups exploit global financial systems and digital infrastructure, with illicit proceeds channelled into property, corporate structures and investment vehicles. For financial institutions, this reinforces the need to treat transnational crime and financial crime risks as interconnected.

5. FCA enforcement will stay tough

The FCA’s enforcement posture shows no sign of easing. Last year’s penalties underline a clear message: regulators care less about whether policies exist and more about whether controls actually work. Scrutiny is increasingly focused on governance, resourcing, data quality and remediation. Financial crime should be treated as a board-level issue, with weak ownership or slow fixes likely to trigger significant consequences.

6. The rise of a new crypto asset regulatory regime

The UK is shifting from limited crypto oversight to full-scale regulation covering issuance, trading, custody and intermediation. In 2025, the government laid out a new crypto asset regime which is expected to come into force in 2027. This means crypto will no longer sit at the margins of financial regulation, but firmly within the regulated sector. It will also create a compressed transition window for firms engaging with digital assets. 

What this all means for UK firms

The UK is entering a more challenging era of financial crime risk. This year’s expectation is clear - understand emerging risks and prove controls work.

Themis supports UK organisations through horizon scanning and regulatory intelligence, as well as targeted technology solutions. Get in touch to learn more.