The Birth of the Universal Language of Financial Crime

Money laundering remains one of the greatest threats to the global economy, fueling organized crime, terrorism, corruption, and tax evasion. Despite continuous efforts, financial institutions have long struggled with fragmented and inconsistent approaches to combating illicit financial activity.

According to the United Nations Office on Drugs and Crime (UNODC), an estimated $800 billion to $2 trillion is laundered annually – representing up to 5% of global GDP.

The impact goes far beyond financial loss. Money laundering distorts markets, increases fraud risks, and undermines economies worldwide. Yet despite these staggering figures, financial institutions have lacked a unified framework for effectively identifying and preventing such activity.

The Rise of the Idea

There is no single answer as to why a universal language for financial crime has not existed – until now.

We believe several key reasons have contributed to this gap:

●      Conceptual vs. Operational Gaps

High-level AML guidelines and conceptual risk frameworks are often disconnected from day-to-day compliance activities. Teams responsible for transaction monitoring, operational processes, and software development lack a single, structured reference –leading to ambiguous or incomplete implementations.

●      Fragmented Approaches

Financial institutions and regulators frequently develop their own interpretations and risk definitions in isolation. This fragmentation results in inconsistent anti-money laundering (AML) controls, duplicated efforts, and limited sector-wide collaboration.

●      Unstructured AML Typologies

Many official typology reports are published in freeform text with little to no labeling. Institutions must interpret and manually adapt this content, making it difficult to convert guidance into actionable detection logic or investigative procedures.

●      Accessibility for Smaller Institutions

While large banks may have the resources to build internal typology databases, smaller institutions often lack the capacity to develop or maintain robust frameworks. Without open, standardized references, these organizations remain disadvantaged in detecting sophisticated money laundering schemes.

What is AMLTRIX?

Recognizing these issues – and drawing inspiration from industries that have successfully addressed similar challenges – the idea for AMLTRIX was born: a free community-driven framework for understanding, detecting, and mitigating illicit financial behavior.

In simple terms, AMLTRIX is an open-source knowledge graph that uses an "adversarial kill chain" approach – a concept borrowed from cybersecurity – to model how criminals launder funds.

AMLTRIX aims to unify the anti-money laundering ecosystem through a transparent, structured taxonomy that brings clarity to complex financial crime behaviors. By standardizing how risks, adversarial techniques, and indicators are described across jurisdictions and institutions, AMLTRIX addresses key gaps in today's AML efforts—including poorly labeled AI training data, fragmented compliance practices, and challenges in privacy-conscious collaboration.

More than 1,400 AML/CFT sources have been analyzed to form the content of the framework.

Breaking the Standards

AMLTRIX defines the adversarial behavior of money launderers through a structured set of interconnected objects.

AMLTRIX AML/CFT framework – abbreviated version as of April 2025.

At the highest level are Tactics, which represent strategic objectives like Placement or Asset Protection. Each Tactic is implemented through Techniques - the concrete methods criminals use to achieve these goals, such as structuring deposits or using shell companies. In some cases, Subtechniques are introduced to describe more granular variations of a technique.

To detect these behaviors, AMLTRIX defines Indicators—also known as red flags—which signal that a particular technique may be underway. These indicators are linked to relevant Data Sources, such as transaction logs, KYC records, to guide where and how detection should occur.

Mitigations represent the controls or actions financial institutions can take to disrupt or prevent specific techniques. These may include enhanced due diligence, transaction monitoring rules, or customer education campaigns.

Each technique is further enriched with contextual layers, including Actors (those involved), Risks (vulnerabilities), Services & Products (financial tools exploited), and Value Instruments (mediums like cash or crypto).

This interconnected model enables a comprehensive understanding for financial institutions, regulators, and analysts, and serves as a practical, intelligence-ready toolkit for mapping laundering behaviors, identifying red flags, and deploying targeted mitigations.

Key Principles of AMLTRIX

AMLTRIX introduces several key principles every compliance specialist should know:

●      The First-of-Its-Kind AML Knowledge Graph

AMLTRIX organizes money laundering tactics and risk indicators in a structured format—like a "periodic table" for financial crime detection.

●      Consolidation of Information

While organizations such as FATF and the Egmont Group publish valuable guidelines, institutions have often worked in silos. AMLTRIX bridges these efforts into a single, universal framework.

●      Bridging Compliance and Technology

By making AML insights machine-readable, AMLTRIX enables the development of AI-powered detection models, enhancing institutional capabilities to prevent financial crime.

●      A Free and Collaborative Initiative

Unlike proprietary tools, AMLTRIX is open to all financial crime professionals, encouraging global contributions and the application of best practices.

●      Proven Principles from Other Industries

Industries like cybersecurity and disinformation analysis have benefited from standardized frameworks. AMLTRIX applies these lessons to financial crime, opening the door for better automation, collaboration, and innovation.

Interest Already Gained

AMLTRIX has already attracted the attention of major regulators, including the Central Bank of Ireland and the Bank for International Settlements (BIS), both of which have recognized its potential to transform AML/CFT practices globally.

The AMLTRIX initiative was showcased at the BIS' Innovation Hub Analytics Challenge 2025. The BIS plays a critical role in shaping global anti-financial crime strategies, particularly through the work of the BIS Innovation Hub.

The challenge brought together private and public sector companies and academic researchers to propose collaborative technology solutions to combat financial crime and simplify compliance.

By offering a structured and transparent approach, AMLTRIX is positioned to become an essential tool in the fight against modern financial crime.

The Future of AMLTRIX

The creators of AMLTRIX are actively exploring which future developments to prioritize. Industry feedback and interest are welcome as the framework continues to evolve. Potential enhancements include:

●      Cross-Border, Privacy-Conscious Threat Sharing

Securely exchanging insights on criminal techniques without exposing sensitive data or compromising privacy.

●      Documented Case Catalogs

Narrative-rich examples that show how adversaries use money laundering tactics in real-world, publicly documented cases.

●      Algorithmic Detection Definitions

Structured detection logic that institutions can implement to ensure consistent and effective monitoring.

●      Synthetic or Aggregated Risk Data

Sharing synthetic datasets and aggregated risk event data to test and validate AML analytics models.

●      AML Data Exchange Standards

Developing operational and interoperable data standards to improve system integration and efficiency.

●      Expansion to Other Financial Crime Threats

Adapting AMLTRIX to domains such as fraud, terrorism financing, sanctions evasion, proliferation financing.

Join the Movement

AMLTRIX represents a paradigm shift in how financial crime is understood and addressed.

With a firm commitment to open-source collaboration, AMLTRIX invites compliance officers, regulators, financial institutions, technology providers, and subject matter experts—including AML & Compliance Professionals, FIUs, Law Enforcement Agencies, Data Scientists, Risk Managers, and Technology Vendors—to join the initiative and help shape the future of AML/CFT.

About the Authors

AMLTRIX was created by AMLYZE, a Software-as-a-Service (SaaS) RegTech company offering a suite of anti-financial crime solutions tailored for all types of financial service providers. Its comprehensive modules include real-time and retrospective transaction monitoring, customer risk assessments, AML/CFT investigations, and PEP, sanctions, and adverse media screening.

The company's products are developed by a team of anti-financial crime experts and former regulators with deep experience in supervising financial institutions and working alongside central banks and law enforcement agencies. This insider knowledge has fueled the creation of cutting-edge technology that significantly streamlines AML/CFT and compliance processes.

Founded in 2019, AMLYZE has been consistently recognized for its innovation in the fight against financial crime.