When Documents Can No Longer Be Trusted: Rebuilding AML/KYC in the Age of AI

In the latest episode of State of the Art, Reseo Co-Founders Pierre-Yves Rahari and Luuk Jacobs examine a challenge that is reshaping the foundations of financial crime prevention: the accelerating breakdown of trust in documents.

Across the investment industry, AML and KYC processes still rely heavily on documentation such as passports, certificates, corporate filings and identification records. Yet artificial intelligence is now making it possible to fabricate these documents with astonishing realism and at scale. As the lines between real and fake blur, the industry faces a fundamental question: what happens when the documents we have always relied on can no longer be trusted?

The Emerging Breakdown of Document Trust

AI now makes it possible to fabricate convincing corporate records, beneficial ownership structures, historic filings and identity documents, all with the appearance of legitimacy. What once required expertise and time is now achievable with readily available tools. The majority of companies remain genuine, but the small percentage of sophisticated falsifications represents a systemic vulnerability.

The implication is profound: Traditional document-driven verification no longer provides the assurance it once did. Email exchanges, PDFs and notarised copies aren’t inherently reliable when the underlying content can be artificially generated or manipulated at scale.

Why the Old Model No Longer Works

The challenge is not simply the documents themselves, but the process behind them. Most AML/KYC workflows remain dependent on information submitted by the investor, creating a single point of failure. Manual reviews are done; however, it is harder to distinguish between genuine documentation and high-quality AI-generated forgeries.

This makes a structural shift unavoidable. Verification must increasingly rely on independently sourced, authoritative data rather than investor-supplied documents. Corporate registries, supervisory bodies and tax authorities offer information tied to regulatory oversight and embedded governance, which provides more durable assurance than documents alone. While no single source is perfect, combining multiple trusted datasets makes falsification significantly harder to sustain.

AI as Part of the Solution

Although AI is a driver of the threat, it is also essential to the defence. Used responsibly, AI can compare information across jurisdictions, flag inconsistencies, detect anomalies in company structures and maintain continuously updated profiles of clients. This opens the door to perpetual compliance, a dynamic model that replaces the current cycle of onboarding followed by years-long gaps before the next review.

Corporate structures and ownership can change dramatically in months. AI-enabled monitoring of independently sourced data means AML/KYC no longer has to lag behind real-world developments.

The Case for Interoperability and Collective Defence

A further weakness in today’s environment is fragmentation. Administrators, transfer agents and asset managers each conduct their own AML/KYC checks, often without visibility into decisions made elsewhere. Fraudsters exploit these gaps.

The industry needs a more interconnected ecosystem, where systems are interoperable and trusted data can be exchanged securely, and through consent, remain GDPR compliant. This does not mean a single shared utility, but rather a collaborative architecture that allows risk signals and verified information to flow between platforms, reducing duplication and strengthening the collective defence against financial crime.

Learning From Other Sectors

Similar challenges have already been addressed in other industries, offering inspiration for financial services. In healthcare, AI models compare scans against thousands of other images to identify abnormalities. A technique that could be used to compare companies across peer groups to detect unusual patterns in structure or behaviour. In agriculture and food supply chains, tokenisation is used to trace products from origin to supermarket, creating tamper-resistant provenance records. The same principles could underpin future approaches to tracking corporate identity and document provenance in financial crime prevention, including their incorporation into blockchain-based systems.

These analogies highlight a broader truth: the technologies needed to rebuild trust already exist. The challenge lies in adapting them to an AML/KYC context.

What Firms Should Do Now

The evolving threat landscape requires boards and executive teams to take a more active stance. Protecting the firm from fraud, money laundering and regulatory exposure is not simply a matter of enhancing checklists. It demands a change in mindset and architecture.

Four priorities emerge clearly:

  1. Shift from document-driven to data-driven verification using independently sourced, authoritative information.
  2. Move toward perpetual compliance, replacing episodic reviews with continuous monitoring of client profiles.
  3. Digitise and simplify AML/KYC processes to reduce friction while strengthening defences.
  4. Collaborate across the ecosystem, developing a collective defence that prevents bad actors from exploiting gaps between firms.

The collapse of document trust is not an isolated threat; it is a systemic one. The firms that respond early with a modern data foundation, smarter technology and collaborative architectures will be best positioned to maintain trust in a world where fraud is increasingly automated.

Click here to listen to the full recording regarding this article.

Financial Crime Goes Global: How Europe Is Fighting Back

In the latest episode of “State of the Art,” Reseo’s podcast on innovation, regulation and trust in investment management, host Pierre-Yves Rahari sat down with Giles Swan, Public Policy and Regulatory Consultant, to explore how financial crime is evolving and how Europe is responding.

In this article, we look at how financial crime has become a truly global and technology-driven phenomenon, how the EU’s new Anti-Money Laundering Authority (AMLA) and AMLD6 directive aim to tackle it, and how technology is reshaping compliance and supervision across the investment industry.

The Globalisation of Financial Crime

Financial crime has long been part of the financial landscape, but its scale and sophistication have changed dramatically. According to the UN Office on Drugs and Crime, money laundering alone accounts for an estimated 2–5% of global GDP — between USD 2 trillion and 4.5 trillion annually.

“Those are huge numbers,” said Giles Swan. “They represent a significant issue not only for governments and regulators, but also commercially for firms that want to remain viable in a fast-evolving landscape.”

What’s new is the globalisation of financial crime. Enabled by technology, perpetrators now operate across jurisdictions, using digital networks to obscure ownership and move funds instantaneously. “We are not just dealing with local actors anymore,” Swan explained. “Technology has turned financial crime into an inherently cross-border challenge — involving both state and private actors with far greater sophistication than before.”

Europe’s Coordinated Response: AMLA and AMLD6

In response to this expanding threat, Europe is reshaping its anti-money-laundering (AML) and counter-terrorist-financing (CTF) framework. The creation of AMLA — the new European Anti-Money Laundering Authority, headquartered in Frankfurt — marks a major shift toward a coordinated, supranational model.

Historically, EU member states managed financial crime at the national level, resulting in divergent rules and supervision. AMLA’s mandate is to harmonise oversight and directly supervise certain high-risk, cross-border entities. “This is about joining up the dots,” said Swan. “The idea is to ensure that regulation keeps pace with the cross-border nature of financial crime, rather than being fragmented by national boundaries.”

Alongside AMLA, the sixth Anti-Money Laundering Directive (AMLD6) and accompanying AML Regulation aim to strengthen consistency across the EU. A key feature is the Ultimate Beneficial Ownership register, designed to improve transparency by requiring firms to identify and verify the individuals behind corporate structures — a move that will have deep implications for investment managers, fund administrators, and service providers.

“These rules demand greater use of technology,” Swan noted. “Manual processes that were once sufficient under earlier directives won’t be enough. Firms will need systems that can handle complex ownership structures efficiently.”

Collaboration, Technology, and Compliance in Practice

As regulations tighten, investment firms are re-evaluating their compliance frameworks. The focus is shifting from reactive reporting to proactive data analysis and technology-driven detection.

“The landscape is inherently technological now,” Swan said. “In the crypto-asset sector, for example, blockchain analytics tools like chain analysis are being used directly to track and prevent financial crime. That’s a model from which the traditional asset management industry can learn.”

He points to a convergence between RegTech (for firms) and SupTech (for regulators). Both sides are exploring how AI, distributed ledger technology, and real-time data can improve risk identification and reduce false positives. “There’s an exciting partnership potential here,” Swan added. “Regulators don’t need to reinvent the wheel — they can build on what the industry has already developed.” 

The Road Ahead: A Smarter Regulatory Future

As enforcement becomes more coordinated, firms can expect more cross-border actions and deeper scrutiny of control frameworks. Yet the shift also presents an opportunity: greater regulatory convergence across the EU could reduce friction for compliant firms and enhance trust with clients and counterparties.

Swan emphasised that boards have a central role to play. “Every board should ask two questions,” he advised. “First, how are our financial crime policies being implemented in practice? Second, what is our weakest link? That’s where the greatest exposure lies — whether in a management company, fund structure, or service provider.”

Ultimately, fighting financial crime requires a balance of vigilance, collaboration, and technological innovation. “The good news,” Swan concluded, “is that regulators and industry are finally moving in the same direction.”

Click here to listen to the full podcast based on this article.

New episode: Regulation Ramp-Up — The Coming AMLA Regulation and Its Impact on the EU and UK

Welcome back to a new season of Reseo’s State of Art podcast — where we speak with industry experts about the ideas and forces shaping the future of investment management.

In this episode, Pierre-Yves Rahari, Co-Founder and Director at Reseo, is joined by Giles Swan, a Public Policy and Regulatory Consultant.

Together, they discuss how the upcoming Anti-Money Laundering Authority (AMLA) regulation — set to take effect in July 2027 — will reshape the regulatory landscape, and what it means for firms, clients, and compliance practices. They also reflect on the evolving relationship between regulation, technology, and financial crime prevention, and how the industry can act now to prepare for what’s ahead.

  • Guest:Giles Swan — Public Policy Consultant, Swan FS
  • Host:Pierre-Yves Rahari— Co-Founder and Director, Reseo
  • Produced by: Melanie Lopes — Sales & Marketing Associate, Reseo

Thanks for listening to the Reseo State of the Art podcast – you can find us here and on Spotify.

Digitalisation is the new era: Are industries keeping up to transform corporate client onboarding?

In a world where digital touchpoints define the client journey, onboarding remains the first true test of innovation.

Opening a personal account with a neo bank has been revolutionised with the smartphone and all we need is our passport, proof of address and the camera on our phone. Based on this input, various checks are carried out in the background and 10 minutes later you can start using your account and a digital bank card.

How different this is for corporate onboarding; papers are sent via email, post and sometimes still even fax, endless requests for clarification leading it to take on average 4-5 weeks before the ok is given. It is a far cry from the retail sector account opening.

Equally, technologies like AI are undermining the traditional ways of manual checking documentation and fake data such as a complete set of fake company structures and documentation can be created in no time undermining the trust in documents[1].

Change is nevertheless on its way due to technological advancements e.g. AI, cloud computing, API’s, detection and zero trust document technology, OCR (Optical Character Recognition and LLM (Large Language Models).

Regulators also pinch in and are pushing for change and moving towards perpetual compliance. The enhanced EU AMLR regulation – aiming to harmonize compliance obligations for banks, crypto-asset service providers, real estate agents, legal professionals, and other obliged entities, Regulation 2024/1624[2] – is just around the corner with implementation by July 2027. Whereas the EU Anti-Money Laundering Authority (AMLA, the first centralised EU authority for direct EU wide supervision of AML/CFT compliance) has just set up a shop in Frankfurt.

Market expectations are shifting, and the need for speed to benefit from market opportunities in investment management, industry trading and corporate banking, to name a few, should not be upheld by paper based processes.

Last but not least, the consistent increase in the cost of AML/CFT compliance can only be mitigated if we address the current outdated way of working.

To move away from the manual checks of documents, we need to shift to a technology driven verification of corporate data and information (not stale documents), to create real-time insights in corporate structures, activities, decision makers and (ultimate) beneficiaries.

The road to change is mired with obstacles of legacy infrastructure, risk averse organisations, current over engineered processes (to be replaced instead of replicated), interoperability of systems and platforms while remaining within the boundaries of legislation like GDPR.

At Reseo, we understand these challenges and we believe that digital onboarding is not just a process but a client experience differentiator whereby the Reseo modular, technology driven, secure and client centric e-ID is a digital wallet that can be shared with any counterparty on the platform. To transform corporate client onboarding, we blend technology and investor-centric services, ensuring continued financial trust while future-proofing the industries for the digital generation. AML/KYC is just our starting point.

 

[1] Xavier Hamori, KYC in 2025: The Collapse of Document Trust, June 1, 2025

[2] Europa.eu. (2024). Regulation – EU – 2024/1624 – EN – EUR-Lex. [online] Available at: https://eur-lex.europa.eu/eli/reg/2024/1624/oj/eng.

Cost of AML KYC processing: Changing the paradigm 

Costs of processing AML KYC are spiralling out of control, and a straightforward digitalisation of existing operations is no longer sufficient to tame these costs. A change of paradigm is now required. That is our belief at Reseo.

In today’s world, it is hard to keep abreast with the changing technology landscape in the investment management industry, let alone the regulation that aims to ensure that technology is not having negative impacts on the investor.

AI is portrayed as the holy grail and at the forefront of every technological development, whereas the EU is issuing a myriad of regulations to ensure the technology is used ethically, which benefits the interest of the consumer and takes into account the privacy of data of individuals.

Some of the regulations already in force or are coming into force in this area are the AI Act (Nov-‘26), Cyber Resilience Act (Dec ‘27), Financial Data Access Regulation (FIDA, Jul ‘25), European Data Act (Sept ’25) and the recently enforce DORA (Jan ’25).

It all can give a feeling that whenever a new technology is being deployed to either improve products, increase client services or save costs, additional costs are incurred to comply with new or changed regulations.

AML KYC cost

The above is definitely applicable to complying with AML KYC regulations. The investment management industry being used for Money Laundering / Terrorist Financing (MLTF) is getting even more sophisticated and could undermine the trust, which is paramount, in the industry. The projected total cost of financial crime across financial institutions worldwide is $274.1 billion, which is an increase of $60 billion in only two years. On top of that fines reached a whopping peak of $12 billion In 2021[1].

Against this sophistication of MLTF stands the still “paper” based process of gathering data to combat MLTF combined with recording the assessment through workflow driven files and data depositories, making for a high risk and costly compliance with regulation.

Digitalisation has been focussing on existing workflows and has not necessarily addressed the inherent inefficiencies of those workflows, whereas the General Data Protection Regulation (“GDPR”) are a further spoke in the wheel. This limits the exchange of data, causing the industry to continue to duplicate data exchange, verification and approval.

A rethink is due

We are all used to travelling the globe and handing over our passports at the border (sometimes with a visa obtained through the internet) to get access to the country we want to visit. Access to multiple countries with only one border check is possible through agreements like Schengen. Yes, participation and collaboration of all stakeholders is paramount and necessary and proven possible.

If the EU can achieve this why would the investment management industry not be able to get this done as well ie create something similar for getting easy access to financial services and investing.

Automating or digitalising is already an inefficient process, and workflows do not sufficiently address the spiralling costs, the fast changing environment and the increasing risk posed by sophisticated MLTF. A rethink is due.

At Reseo we think this is possible and to that end, we have created the e-ID, a go anywhere digital corporate passport. No endless requesting and sending around the documents and data that need to be verified, they are all captured and kept up to date in one corporate e-ID, verified by the e-ID Owner, confirmed by Reseo and approved by the e-ID User.

Taking out duplication, using state of the art AI, creating transparency for all participants, making compliance perpetual, reducing materially the cost and keeping or even heightening the trust in the industry and all its stakeholders.

A worthwhile cause to change the paradigm.

 

 

[1] LexisNexis: True cost of financial crime compliance global study, 2023

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