These non-bank settlement methods operate through agents rather than regulated financial institutions, creating significant blind spots for law enforcement. The report highlights a shift toward professionalization, where underground banking mirrors the sophistication of legitimate firms. Criminals now leverage encrypted communications, anonymity tools, and cryptocurrencies to move illicit funds with greater speed and opacity.
Complicating efforts to disrupt these networks is the increasing involvement of professional intermediaries. Lawyers, accountants, and real estate agents are frequently cited as key facilitators who help integrate dirty money into the formal economy. FATF member states are calling for a more aggressive regulatory response to target these service providers, as the integration of fintech has made informal systems more resilient against traditional oversight mechanisms.
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