The Riffle
Professional Money Laundering (PML) is becoming increasingly sophisticated, with underground banking and Hawala and Other Similar Service Providers (HOSSPs) being exploited by criminal networks to transfer and settle illicit value.
The September 2026 FATF findings highlight how these networks are evolving beyond traditional cash-based models, increasingly integrating virtual assets, fintech platforms, bank accounts and digital tools.
Key Highlights
Digital Hawala is growing
Encrypted communication, virtual assets and AI-based tools are making informal value-transfer networks faster and harder to trace.
Formal and informal finance are converging
Underground networks increasingly use bank accounts, fintech platforms, payment service providers and virtual IBANs to settle and layer proceeds.
Money laundering is becoming professionalised
Specialised facilitators are offering sophisticated laundering infrastructure across jurisdictions—effectively creating “money laundering as a service”.
Settlement methods are diversifying
Networks may settle balances through cash, trade, gold and luxury goods, formal banking channels or stablecoins and other virtual assets.
Criminal use is expanding
Beyond drug trafficking, these networks are increasingly linked to cybercrime, fraud, tax evasion, undeclared work and terrorist financing.
Enforcement is shifting towards system-wide disruption
Authorities are increasingly looking beyond individual transactions and using barrier models, multi-agency cooperation, blockchain analytics and public-private partnerships to disrupt entire laundering networks.
Next Steps
Financial institutions and competent authorities should strengthen their understanding of emerging PML typologies, enhance detection of hybrid financial flows and improve information-sharing across the public and private sectors.
At the same time, proportionate regulation and accessible formal remittance channels remain important to avoid pushing legitimate users towards unregulated alternatives.
Important Dates
September 2026 – FATF report findings on Professional Money Laundering, underground banking and HOSSPs.
Riffle Takeaway
As underground banking becomes more digital and interconnected with formal finance, tackling professional money laundering requires following the entire network not just the transaction.
