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The Use of AI to Bypass Customer Due Diligence Checks

AI and compliance
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In April 2026, the Joint Money Laundering Intelligence Taskforce (JMLIT) published a second edition Amber Alert (0801-NECC) covering the use of Artificial Intellience (AI) to bypass customer due diligience (CDD) checks.

This Alert was a follow up to the first edition, published in October 2024 (0752-NECC), and is based on the findings of a public-private partnership cell, which sought appropriate data from members to answer key questions on this threat. The Alert used data from members to estimate the overall scale of the threat on the UK financial sector, and confirmed the threat as a current one not a theoretical one.

AI has been used to manipulate identity documents and create deepfakes, allowing criminals to impersonate real individuals or create synthetic personas, masking the criminal’s identity and providing evolving challenges to CDD processes. Accounts, created using AI manipulated images or video, have facilitated different frauds and laundered proceeds from drug trafficking and other crimes.

If you or your institution identifies activity which may be linked to the detail in this report, and there is a suspicion of money laundering or terrorist financing, you may wish to make a Suspicious Activity Report (SAR). If you decide to make a report in this way, you should adopt the usual mechanism for doing so, and it will help our analysis if you would include the reference 0801-NECC for this Alert within the relevant field on the NCA SAR Portal.

 

Source: UK Financial Intelligence Unit

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