What the Anti-Financial Crime Community Must Do Now

Four articles in, the picture is clear. Young people are being systematically recruited into the infrastructure of organised financial crime. The scale is significant, the mechanics are sophisticated, and the systems designed to protect young people are not fully equipped to do so. The anti-financial crime community has the knowledge, the tools, and the reach to change that, but only if it acts collectively, and only if it is willing to engage with the full complexity of the problem.

This is a call for a fundamental shift in how the profession approaches youth financial exploitation.

What financial institutions need to do

Detection frameworks must be updated to incorporate the human architecture of Account Muling recruitment. Transaction anomalies remain important signals, but a customer being a student is not a red flag in itself. Context, combined with behavioural patterns such as sudden large inflows followed by rapid outward transfers, is what matters.

Beyond detection, institutions need to ask a harder question before filing: is this person a perpetrator, or a victim? A new protocol is being developed to make it easier for statutory services to notify a bank when someone is a victim of financial exploitation, ensuring that victims are not unfairly penalised if exploitation activity is detected on their account. Banks should be active participants in developing and implementing that protocol, not passive recipients of it.

Customer-facing staff, particularly those working in branch, telephony, and digital support channels, need training that enables them to recognise vulnerability indicators in young account holders and to respond in a way that surfaces help rather than triggering immediate enforcement.

Institutions also have a responsibility to educate their customers, particularly younger account holders, before exploitation occurs rather than responding to it after the fact. This is where The Crooks Project offers something concrete and practical. Financial institutions can join the initiative directly, access a suite of ready-made resources, and deploy them through their own customer-facing channels. Putting that kind of evidence-based, real-world content in front of young customers costs far less than the downstream consequences of Account Muling activity on their accounts. It is also the right thing to do.

What compliance and fraud teams need to do

Invest in understanding, not just detection. The research gap identified in Article Three is real, and it can only be closed if the profession actively contributes to building the evidence base. That means engaging with organisations like The Crooks Project, sharing intelligence through appropriate channels, and supporting cross-sector data initiatives that connect financial intelligence with safeguarding insight.

It also means advocating internally for a victim-centred approach to Account Muling cases involving young people. The government recognises exploited children as victims. Financial institutions should ensure that recognition is reflected in their own policies and procedures.

What the profession as a whole needs to do

Financial crime does not operate in silos, and neither should the response to it. The financial exploitation of young people connects fraud prevention, AML, safeguarding, education, law enforcement, and policy, and it can only be addressed through genuine, sustained, cross-sector collaboration.

Financial exploitation networks connect fraud, financial crime, and money laundering into a single criminal ecosystem. Scammers employ victims of human trafficking. Those defrauded through investment scams are drawn into further exploitation. The ecosystem logic works in both directions: dismantling one strand weakens the others.

That means the anti-financial crime community must actively engage with the educational and safeguarding sectors, not as external stakeholders, but as partners with shared operational interests. It means supporting initiatives like The Crooks Project that are generating the qualitative insight the profession needs. And it means using the collective voice of the field to push for policy and regulatory frameworks that properly distinguish between exploited young people and the criminal networks that exploited them.

The Crooks Project and this conversation

The Crooks Project exists to change the way young people, and the professionals around them, understand and respond to financial exploitation. Built on real cases and delivered through powerful film-based learning, the programme has already reached young people and safeguarding professionals across the UK, helping them recognise the tactics, spot the warning signs, and intervene earlier.

But prevention alone is not enough. The financial crime community has a critical role to play, and that is the conversation this series has been building towards.

Youth financial exploitation is growing. It is under-researched. And the profession’s response to it, while improving, is not yet commensurate with the scale of what is happening. Behind a significant and growing share of the estimated £9.4 billion stolen from UK consumers in the past twelve months are the young people we have been discussing across this series.

If you are a Money Laundering Reporting Officer, a Head of Fraud, a compliance professional, or someone working at the intersection of financial crime and policy, this is not a peripheral issue. It sits at the heart of what your work is for.

The financial crime community has the tools, the reach, and the influence to disrupt exploitation networks at scale. What it needs is the collective will, and the right connections, to do so. The Crooks Project is committed to being part of that effort.

This article series is proudly sponsored by the We Fight Fincrime Association, whose members are the practitioners, experts, and organisations working to ensure that financial crime is tackled as the shared, systemic challenge it truly is.

Find out more about The Crooks Project at thecrooksproject.org and sign up for your free membership here. 

Join the WFFA community of professionals working to build a more connected, informed, and effective response to financial crime. Become a member here.