FATF ¦ Launching the FATF's Roadmap 26-28 on Combatting Fraud

FATF ¦ Launching the FATF's Roadmap 26-28 on Combatting Fraud

A New Phase in Global Anti-Financial Crime Action

The launch of the FATF’s Roadmap 26–28 marks a clear shift in priorities. Fraud is no longer being treated as a peripheral crime that sits outside the main anti-money laundering agenda. It is now being recognized as one of the most urgent and damaging threats to financial integrity, consumer protection, and national security.

That shift matters because fraud is not only large in scale, but also fast, adaptive, and deeply interconnected with other forms of criminality. The UK presidency of the FATF has placed fraud at the center of its agenda for the next two years, alongside improving the risk-based approach (RBA) and strengthening information sharing. The message from the launch event was direct: the global system must move from reacting after the fact to preventing fraud at scale, disrupting it earlier, and recovering stolen funds more effectively.

Why fraud is now a FATF priority

The case for prioritizing fraud is hard to ignore. The global cost is estimated at $500 billion a year. Fraud is also the predicate offense in 90% of FATF mutual evaluations in the most recent round, which shows how widely it cuts across jurisdictions.

But the harm is not only financial. Victims can lose life savings, face emotional trauma, and suffer long-term harm. In scam compounds, people are trafficked, coerced, and held in conditions that amount to modern slavery and forced labor. Fraud also threatens financial inclusion, undermines trust in digital services, and in many countries has become a national security concern.

Another reason fraud is now a separate strategic focus is that it behaves differently from many other predicate offenses. In fraud cases, laundering often happens at the same time as the scam itself. That means the usual follow-the-money model needs to become faster, more connected, and more preventive.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"FATF’s new Roadmap 26–28 puts fraud at the center of the global anti-financial crime agenda. The launch made clear that the priority is not just to detect fraud after the fact, but to prevent it faster, share information more effectively, and recover stolen funds before they disappear.

The discussion also showed that the strongest responses already rely on coordination across banks, telecoms, tech platforms, law enforcement, and FIUs. Over the next two years, FATF will focus on scaling these working models, improving the use of its existing tools, and turning more intelligence into real-world disruption."

The FATF wants a broader toolkit, not a new bureaucracy

A central theme of the launch was that the FATF already has strong standards and tools. The task now is to use them better and adapt them to the fraud threat.

Those tools include payment transparency, which helps trace transactions and detect illicit movement more quickly. They also include regulation of virtual assets (VAs), which is important because crypto assets are commonly used both in the commission of fraud and in laundering the proceeds. Asset recovery powers are another key lever, including the ability to freeze and confiscate proceeds more quickly in some cases without a prior conviction. Beneficial ownership transparency also remains essential, especially when fraud proceeds move through layered structures.

The FATF also highlighted the value of partnerships. Better cooperation between public authorities and private sector firms can significantly improve detection and disruption. National anti-scam centers were presented as a particularly useful model, especially where they bring together law enforcement, regulators, financial institutions, telecoms, tech platforms, and other relevant actors in one coordinated structure.

Speed is now a defining issue

If there was one point that came through repeatedly, it was speed. Fraud happens fast, and recovery often depends on acting within minutes or hours, not days.

The Thailand example was striking. According to the discussion, 50% of fraud losses are already out of the country within three minutes of a transfer, and victims often only realize they have been scammed around 20 hours later. That reality changes the design of the response. It means financial intelligence must be more real-time, information sharing must be more immediate, and operational coordination must be far more agile.

This also raises an important question for the future of the traditional suspicious transaction reporting model. Speakers argued that while STRs remain valuable, fraud requires a different kind of financial intelligence framework. One that can work with large data sets, detect patterns across multiple institutions, and support immediate intervention.

Public-private cooperation is becoming the norm

A major takeaway from the launch was that the most effective fraud responses already rely on public-private partnership. In Australia, Nigeria, Thailand, the UK, and elsewhere, anti-fraud work is increasingly built around shared intelligence, joint analysis, and coordinated intervention.

In the UK, the online crime command is built on a public-private model that brings together finance, telecoms, big tech, insurance, and crypto. In Australia, regulators have used AML powers to gather large data sets from multiple sectors and apply controls to high-risk channels, including digital currency exchanges. Thailand’s central fraud registry brings together money trails and account data to help identify mules and new victims. Nigeria has strengthened joint action through its FIU and cross-agency coordination, while also working closely with international partners such as the UK.

The message was consistent across jurisdictions: fraud cannot be beaten by one sector acting alone.

Information sharing is useful only if it leads to action

One of the clearest themes from the event was that information sharing must have a purpose. Sharing data for its own sake is not enough. The goal is disruption.

That means moving beyond isolated bilateral arrangements and toward networks that can support multiple parties at once. It also means involving sectors that sit outside the traditional AML perimeter, especially telecoms, social media, digital platforms, and other parts of the tech ecosystem that often see the earliest signs of a scam.

There was also a practical point about legal certainty. Many stakeholders said that privacy, competition law, defamation, negligence concerns, and uncertainty around data protection rules still make organizations cautious. Several speakers argued that data protection authorities should be brought in as partners rather than treated as blockers. Clear guidance, safe harbors for good-faith sharing, and short-form support such as FAQs were all suggested as ways to unlock faster collaboration.

Virtual assets remain a weak point, but also part of the solution

Virtual assets came up repeatedly as both a risk and a tool. They are often used by fraudsters because they can move quickly and across borders, but they are also becoming a focus for better regulation and more effective disruption.

Nigeria described work on regulatory controls at the fiat-crypto intersection, as well as a kill-chain protocol designed to support early detection and freezing. Australia referred to controls applied across digital currency exchanges when fast-moving flows were identified. In the asset recovery panel, a company described blockchain-based disruption networks that can freeze funds directly on chain and propagate intelligence to virtual asset service providers (VASPs) globally.

The common view was that FATF standards on virtual assets are important, but more needs to be done to ensure they are implemented consistently and effectively.

Asset recovery needs to become faster and more cross-border

The asset recovery session showed that the global network already has useful mechanisms, but they are still not being used to their full potential.

Interpol described I-GRIP , a global stop-payment mechanism that connects 196 member countries in a 24/7 network to intercept funds before they disappear. The Egmont Group’s rapid response program was presented as another key tool, enabling FIUs to exchange just enough information quickly to trace proceeds and support freezing action. Luxembourg emphasized the need for stronger multilateral information sharing, not just bilateral exchange. Singapore highlighted the value of anti-scam center connectivity through Frontier+ .

The main gap is not the absence of tools. It is the uneven use of those tools, the need for more awareness, and the need for better legal and operational frameworks that allow action across jurisdictions at speed.

The human side of scam compounds must not be forgotten

A powerful part of the launch was the discussion of scam compounds and the people trapped inside them. Survivors and human trafficking experts explained that these sites are not just locations for fraud, but often sites of forced criminality, forced labor, and sexual exploitation.

The information survivors can provide is highly valuable. They can identify trafficking routes, compound locations, scam methods, and other criminal activity linked to the same networks. That intelligence can support arrests, sanctions, and broader investigations. It also reminds policymakers that fraud is not only about money movement. It is about human harm.

What happens next

The FATF’s roadmap is ambitious. Between now and October, the focus is on scam compounds and on bringing together stakeholders so efforts are complementary rather than duplicated. By February 2027, the work will expand to cyber-enabled fraud more broadly, with a clearer picture of good practice, key gaps, and priority actions. From February 2027 to June 2028, the focus shifts to implementation.

The FATF also plans to use its assessment and follow-up processes more actively, to push members not only toward compliance on paper but toward real-world effectiveness. A private sector consultative group will help guide the project, and a larger global response event is planned for spring 2027.

A practical agenda for the next two years

The launch of Roadmap 26–28 made one thing very clear: fraud is a global financial crime priority that demands faster coordination, broader partnerships, and more operationally useful intelligence.

The challenge is not lack of effort. It is coordination, speed, and scale. The FATF’s role over the next two years will be to help align existing efforts, reinforce what already works, and push the system toward earlier intervention and better outcomes for victims.

That is a demanding task, but the direction is now set. The next phase will be judged not by how many meetings are held, but by how much fraud is prevented, how much money is recovered, and how effectively the global network can act together when criminals move fast.

Talk copyright holder(s): The Financial Action Task Force (FATF)
The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
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Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.