This has been one of the most structurally significant weeks in financial crime policy in recent memory. The United States has fundamentally reorganised how it prosecutes fraud, the UK has launched its most ambitious counter-fraud architecture to date, and enforcement actions on both sides of the Atlantic signal a clear pivot from reactive policing to systemic disruption. Below is what happened, and what it means.

The US Restructures Fraud Prosecution, and the Implications Are Significant

On 7 April, the Department of Justice formally launched its National Fraud Enforcement Division, absorbing and reorganising components of the Criminal Division’s Fraud Section. The new division includes a National Fraud Detection Center – a permanent, prosecutor-led, multi-agency data-analytics team. Its head, Assistant Attorney General Colin McDonald, put it bluntly:

“No longer will the Department be uninterested in low levels of fraud; we will be interested in all of it.”

On the same day, the division announced enforcement actions targeting approximately $500 million in healthcare fraud, COVID relief abuse, and benefit programme schemes, including the largest COVID-19 tax relief fraud case ever tried – a New Jersey tax preparer sentenced to 12 years for seeking more than $170 million in fraudulent refunds.

This restructuring is an attempt to address one of the central problems in fraud enforcement: jurisdictional fragmentation. Fraud has historically fallen between institutional cracks – too complex for local prosecutors, too low-value for federal attention. The new structure, with its 14-day reporting requirements and mandatory prosecutor detachments from every US Attorney’s Office, is a direct attempt to close the enforcement gap that rational choice theory tells us offenders have long exploited.

This sits alongside two executive orders: one establishing a Task Force to Eliminate Fraud (chaired by Vice President Vance, 16 March 2026) targeting federal benefit programmes, and another on combatting cyber-enabled fraud by transnational criminal organisations (6 March 2026), which mandates a 120-day action plan to disrupt overseas scam operations.

Whether this centralised approach produces results will depend on whether the analytics capability matches the prosecutorial ambition. Detection without capacity is just surveillance.

FinCEN’s AML Overhaul: The Biggest Regulatory Shift in Decades

On 7 April, FinCEN issued a Notice of Proposed Rulemaking substantially revising anti-money laundering and counter-terrorism financing programme requirements for all financial institutions under the Bank Secrecy Act. The FDIC simultaneously approved the rule, jointly with the OCC and NCUA.

This is a wholesale modernisation of the AML framework – the most significant since the BSA’s enactment. It signals a shift from prescriptive, checkbox compliance towards risk-based, outcomes-focused obligations. For criminologists, this matters because it addresses a long-standing critique: that AML regimes generate enormous volumes of suspicious activity reports (SARs) that are rarely actionable. The question is whether this reform will prioritise intelligence quality over reporting quantity.

FinCEN’s Record $80 Million Penalty: A Case Study in Enablement

FinCEN’s $80 million penalty against Canaccord Genuity LLC, the largest ever imposed on a broker-dealer for BSA violations, deserves close attention. The firm failed to file at least 160 SARs related to OTC securities over a six-year period (2018–2024), despite repeated FINRA exam findings. Two compliance employees falsified records to mislead regulators.

Criminologically, this is a textbook example of what Sutherland would recognise as institutional enablement. The firm did not merely fail to prevent fraud, its structural deficiencies allowed illicit actors to perpetrate and profit from fraud schemes affecting investors and the broader market. The penalty structure, $80 million headline, $35 million net after SEC and FINRA credits, reflects the multi-agency reality of financial crime enforcement, where parallel proceedings increasingly function as force multipliers.

Swiss Bank MBaer: Sanctions Evasion and Institutional Complicity

FinCEN’s proposed rule to sever MBaer Merchant Bank AG’s access to the US financial system , the first use of Section 311 special measures against a Swiss bank, is a remarkable enforcement moment. MBaer allegedly facilitated over $100 million in transactions for illicit actors linked to Russia, Iran, and Venezuela. FinCEN describes the bank as a “critical access node to the US dollar for a wide variety of illicit actors.”

What makes this case criminologically distinctive is the alleged concealment: MBaer purportedly stored its Russian client data in a hidden manner and may have intentionally concealed information from its own regulator, FINMA. Shortly after the designation, FINMA withdrew MBaer’s licence and ordered liquidation , citing “serious, systematic shortcomings.” This is not a compliance failure – it is alleged institutional complicity in sanctions evasion. The distinction matters for how we theorise enablement in financial crime.

The UK Fraud Strategy 2026–2029: £250 Million and a New Architecture

The UK Government published its Fraud Strategy 2026–2029 on 9 March, committing £250 million over three years to tackle what remains the country’s most prevalent crime type – accounting for 45% of all recorded crime in England and Wales, costing the economy over £14 billion annually.

The centrepiece is the Online Crime Centre, launching this month (April 2026), bringing together the NCA, GCHQ, the National Cyber Security Centre, banks, telecoms, and tech firms under one coordinated structure for the first time. The strategy’s three pillars, Disrupt, Safeguard, Respond, represent a shift from awareness campaigns to structural intervention.

From a situational crime prevention standpoint, the most significant element is the expectation that telecoms providers will deploy network-level controls to block fraudulent traffic upstream. SIM-swapping, number spoofing, and VoIP abuse are explicitly in scope. This treats telecoms infrastructure as a primary crime enabler, which it is, and shifts prevention obligations to the entities that control it.

The strategy also signals new international cooperation: agreements with Nigeria and Vietnam to share intelligence on fraud networks have already resulted in arrests and scam compound disruptions.

INTERPOL’s Africa Operation: 651 Arrests and the Scale of Displacement

INTERPOL’s Operation Red Card, involving 16 African countries, netted 651 arrests and recovered $4.3 million, with investigations exposing scams linked to over $45 million in financial losses. Separately, Operation Synergia III (72 countries, July 2025–January 2026) led to 94 arrests, the seizure of 212 devices and servers, and the takedown of 45,000 malicious IP addresses.

INTERPOL’s 2026 Global Financial Fraud Threat Assessment warns that AI-enhanced fraud is growing at 4.5 times the rate of traditional schemes, and that cross-border collaboration among criminal groups is accelerating. The report identifies the global expansion of scam centres, often staffed by trafficking victims, as a defining feature of the current threat landscape.

These operations are important, but displacement theory cautions against celebrating arrest numbers in isolation. The question is always: where does the displaced activity resurface?

Consumer Fraud: The Numbers Are Getting Worse

The FTC’s testimony before the Joint Economic Committee (25 March) reported that in 2025, US consumers submitted 3 million fraud reports with $15.9 billion in reported losses – up from $12 billion the previous year. Investment scams accounted for the highest losses at $7.9 billion. Imposter scams remain the most frequently reported category, with $3.5 billion in losses.

Meanwhile, FBI data shows $16.6 billion in total fraud losses in 2024, a 33% annual increase, with crypto-related fraud alone at $9.3 billion (up 66%). Adults over 60 lose more than any other age group.

These figures are certainly underestimates. As AARP’s February 2026 survey found, 55% of romance scam victims never report. Shame is the primary barrier. The dark figure of fraud remains one of the most significant challenges for both measurement and prevention.

The EU’s AML Transformation: AMLA and the Single Rulebook

The EU’s Anti-Money Laundering Authority (AMLA), headquartered in Frankfurt and operational since July 2025, aims to be fully functional by 2028, at which point it will directly supervise 40 EU financial institutions deemed highest risk. The new AML Regulation (AMLR 27) applies from July 2027, introducing a Union-wide EUR 10,000 cash payment cap, lower CDD thresholds, and, for the first time, bringing sanctions compliance explicitly within AML regulations.

For those studying regulatory convergence, the EU’s approach is the most ambitious attempt at harmonised financial crime prevention ever undertaken. The A&O Shearman analysis provides a useful overview of how this interacts with the UK’s parallel but separate MLR reforms. The post-Brexit divergence in AML frameworks between the UK and EU is creating new coordination challenges, and potential regulatory arbitrage opportunities.

Scam Ads at Scale: Meta and the Platform Accountability Deficit

The bipartisan SCAM Act introduced in the US Senate (Senators Gallego and Moreno) would require online platforms to verify advertiser identities and establish processes for reviewing fraud reports. This follows a Reuters investigation finding that Meta delivered an estimated 15 billion scam ads per day to users in 2024 and failed to follow up on 96% of valid fraud reports.

Consumer Reports has separately found that a majority of free or low-cost AI voice cloning tools lack meaningful safeguards against fraud. The convergence of platform-enabled advertising fraud and AI-powered impersonation tools represents what routine activity theory would describe as a near-perfect convergence of motivated offenders, suitable targets, and absent guardianship – at industrial scale.

New Research Worth Reading

A paper published this month, Criminal practices against women masquerading as romance (Alikhadzhiyeva, 2026), proposes a criminological classification of female victims of romance-based criminal schemes based on the criterion of “trust” victimhood. It examines how deep psychological needs are exploited across catfishing, investment fraud, and even terrorist recruitment. This resonates directly with the trust exploitation frameworks I have been developing in my own work on fraud vulnerability.

Also of note: Decentralized Crime: Fraud, Cybercrime and Legal Enforcement (Mohamed, 2025) applies Strain Theory, Routine Activity Theory, and Rational Choice Theory to DeFi-enabled financial crime – a useful framework for understanding how blockchain ecosystems create new criminal opportunity structures.

And for those tracking mortgage fraud in the UK: Gilbert and Levi’s empirical study of social networks within organised crime groups involved in mortgage and property fraud offers rare primary data on how these networks are actually organised.

Worth Watching

The DOJ’s 90-day deadline for legislative recommendations to strengthen fraud laws (due early July). This will signal whether the US is serious about structural reform or whether this is prosecutorial theatre. ([Sidley Austin overview](https://www.sidley.com/en/insights/newsupdates/2026/04/white-house-and-doj-announce-sweeping-new-anti-fraud-initiatives))

The UK’s Online Crime Centre is launching this month. The model of embedding private sector intelligence alongside law enforcement is promising but untested at this scale. UK Fraud Strategy (https://www.twobirds.com/en/insights/2026/uk/uk-fraud-strategy-2026-2029—what-businesses-need-to-know)

AI voice cloning and deepfake video in romance fraud. The FBI confirmed in February 2026 that criminals are now using AI-generated voice messages in scam schemes. Crystal Intelligence (https://crystalintelligence.com/thought-leadership/crypto-romance-scams-in-2026-ai-and-the-new-threat/)

AMLA’s risk assessment methodology, due to be finalised this year, which will determine which 40 EU financial institutions face direct supranational supervision from 2028. Reuters (https://www.reuters.com/sustainability/boards-policy-regulation/europes-anti-money-laundering-body-set-be-fully-operational-2028-2026-02-04/)