Illicit Financial Flows Linked to Atrocity Crimes: Enabling Conduct and Money-Laundering Risks
A new white paper from the Global Coalition to Fight Financial Crime, in collaboration with Lex Collective, “Illicit Financial Flows Linked to Atrocity Crimes: Enabling Conduct and Money Laundering Risks”, examines how atrocity crimes are not only human rights violations—they are profit-generating systems sustained through complex financial networks. Proceeds from crimes such as genocide, war crimes, and crimes against humanity are generated, moved, and laundered through the global financial system—including banks, trade channels, corporate structures, and emerging technologies like crypto.
Key highlights:
Typologies and red flags linked to atrocity finance
Gaps in AML frameworks and FATF standards
Practical recommendations for policymakers, FIUs, and the private sector
Case studies illustrating real-world risks
A central call to action: explicit recognition of atrocity crimes as predicate offences under FATF standards to strengthen detection, enforcement, and accountability.
This is an essential read for compliance professionals, policymakers, and financial institutions working at the intersection of financial crime and human rights.
We want to thank all the expert contributors who authored the paper, Kristin Rosella, Roberta Baldacchino, Zhanna Kondzirska, Tim Louthan, Dinara Kurakbayeva, Ruth Alves da Mota, Richard Sanders, Michal Gromek and Ling Ling Li and Yanis Lunetta for editorial support.
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