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AML Alert – Artificial Intelligence being used to bypass CDD checks

28 May, 2025

As ever, criminAs ever, criminals intent on laundering money will use whatever means available to them avoid detection, including Artificial Intelligence (AI).  As AI becomes more sophisticated and those with criminal intent become more adept at deploying it, there is an increasing trend in its use to bypass Client Due Diligence Checks (CDD). 
The Legal Services Advisory Group (LSAG) has recently published an intelligence report which highlights a growing trend in the use of ever more sophisticated AI to circumvent CDD. Detecting such cases is becoming increasingly difficult, however there are several indicators to look out for, which should be weighed in the balance with other relevant information when considering CDD.  

The intelligence report is an ‘OFFICIAL’ classified document under the United Kingdom’s Government Security Classification System which means that we cannot publish it or its contents in this newsletter.  We are however able to provide Money Laundering Reporting Officers (MLROs) with helpful information about the indicators which can be used to help spot the possible use of AI when carrying out CDD checks.

We strongly encourage all MLROs to contact the CLC’s dedicated AML address as a priority to receive further information and guidance on this issue aml@clc-uk.org.

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