The battle against financial crime is often seen as a regulatory obligation or a test of technical capability. In reality, it is far more complex than this.
Effective compliance is ultimately a response to human behaviour, personal vulnerabilities and the gaps that exist across financial systems.
According to ComplyAdvantage, treating financial crime purely as a compliance checklist risks overlooking the real-world dynamics that allow illicit activity to take place.
These themes were explored in a candid fireside discussion at the CATALYST event series, where criminologist and financial crime expert Dr Nicola Harding spoke with Jodie Gayet, a former fraudster who now works as an advocate and educator. Their conversation highlighted why compliance frameworks must be designed with a deeper understanding of human behaviour, rather than relying solely on rules, thresholds and technology.
Jodie’s personal story offered a powerful illustration of how financial crime can emerge from a convergence of pressure, opportunity and weak controls. What began as a large gambling win at the age of 18 escalated into a long-term addiction and, eventually, involvement in insider fraud and consumer scams. Her experience underscored how individual vulnerabilities, when combined with regulatory blind spots, can create the conditions for sustained criminal activity.
Several critical weaknesses commonly seen in financial crime controls were evident in her case. Gambling addiction, for example, remains an underappreciated risk indicator for non-organised fraud, despite almost half of the UK population gambling regularly and around 4% facing elevated levels of harm. Internal risks were also exposed, with insufficient oversight of employees’ access to dormant accounts enabling illicit transfers to go undetected. In parallel, weak authentication and know your customer (KYC) controls on online platforms created fertile ground for consumer scams.
These issues point to a broader challenge: fragmented regulation and siloed compliance approaches can unintentionally create loopholes. Disconnects between safer gambling frameworks and anti-money laundering and countering the financing of terrorism (AML/CFT) requirements are one example. Minimal KYC at onboarding, combined with surface-level transaction monitoring, can allow criminals to bypass controls by using offshore services or third-party providers that fall outside domestic safeguards.
As a result, basic measures such as card blocks or lightweight identity checks are rarely sufficient deterrents for determined offenders. Effective compliance programmes must consider how systems are actually used and misused, not just how they meet regulatory minimums. This requires organisations to foster a culture of compliance that values empathy, expertise and challenge. Teams need the resources, authority and tools to question existing processes and strengthen controls before they are exploited.
Technology has a critical role to play, particularly as criminals increasingly leverage artificial intelligence to scale and refine their methods. Deepfakes, AI-driven impersonation and sophisticated social engineering attacks are becoming more common, raising the stakes for financial institutions. To keep pace, compliance teams must adopt advanced AI capabilities while breaking down internal data and technology silos.
When deployed strategically, AI can enhance customer due diligence at onboarding through better data matching and dynamic risk scoring, support continuous monitoring as customer profiles evolve, and improve transaction monitoring by identifying complex patterns at scale. Agentic AI can also streamline remediation by clearing low-risk alerts, allowing human analysts to focus on higher-risk investigations.
Ultimately, grounding compliance strategies in real-life stories and human insight may be one of the most effective ways to make them resilient, ethical and fit for purpose.
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