FATF opened the launch of its 2026-2028 agenda with a single number: $1trn. That is what scams are estimated to cost globally every year, and cross-border data sharing now sits alongside a renewed commitment to risk-based supervision as one of three named priorities for the incoming UK Presidency.
According to Consilient, weeks earlier, UNODC had made a parallel move. Under UN General Assembly Resolution 80/227, illegal mining and mineral trafficking were placed before the General Assembly alongside timber, fisheries and waste crime, framed explicitly as a security, justice and state authority issue rather than a conservation matter.
Consilient recently discussed the 2026 AML agenda for banks, talking about gold laundering, FATF, and UNODC.
A new IISS report puts a figure on the problem UNODC is describing: illicit gold mining now generates proceeds of between $12bn and $48bn a year, a range that has climbed alongside gold prices, up more than 182% over five years. In Peru alone, illicit proceeds nearly tripled, from $4.8bn in 2024 to $12bn in 2025, while in Colombia illegal gold mining now out-earns cocaine for organised crime groups. More than 80% of financial institutions carry exposure to this risk, yet 40% have not yet acted on it.
UNODC names five typologies driving the trade: illegal extraction, origin mislabelling, false documentation, corruption, and laundering through supply chains that present as legitimate. Corruption is often what makes the false documentation possible in the first place, while origin mislabelling is the mechanism that lets the other four survive contact with a refinery.
Once illicit gold is refined and blended with legitimate material, its physical origin becomes extremely difficult to recover. The value, however, does not disappear, so the documentary and financial trail becomes the more important signal, one that traditional trade-based money laundering controls, built around invoicing anomalies, are not designed to catch once the underlying commodity itself is already fungible.
For correspondent banks and trade finance teams, the exposure runs through three groups: banks clearing payments for refiners and exporters in minerals-producing jurisdictions, teams issuing letters of credit against multi-country documentation chains, and onboarding teams assessing newly incorporated exporters whose trading history doesn’t yet match the volumes they claim to move. That last scenario, a young entity receiving substantial inbound payments before it has an established customer base, is precisely where detection is easiest, before a trading history builds up around it.
The underlying challenge for both institutions is the same: relevant signals are scattered across refiners, exporters, banks and customs authorities in different jurisdictions, with no single participant able to see the whole picture. The direction both FATF and UNODC are pointing towards is collective intelligence, allowing institutions to learn across fragmented data without pooling or exposing it directly, rather than simply gathering more data within each institution’s own walls.
Read the full Consilient post here.
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