Executive summary
What 100 financial crime leaders are facing
An industry adapting to a faster-moving threat landscape
Financial crime continues to evolve at pace, driven by advances in artificial intelligence, increasingly sophisticated attack methods and a rapidly changing regulatory landscape. To understand how organisations are responding, The Payments Association surveyed 100 senior financial crime leaders from across the UK financial services sector.
The findings reveal an industry under sustained pressure. While organisations are increasing investment in fraud prevention and AI capabilities, many believe attacker capability is advancing faster than their own ability to respond. At the same time, uncertainty around regulation, governance and cross-industry collaboration continues to hinder progress.
This summary highlights the report’s principal findings and the strategic implications for organisations responsible for protecting customers, strengthening resilience and preparing for the next phase of financial crime.
Key findings
AI is changing financial crime faster than organisations can respond.
76% say AI-enabled fraud is outpacing their current response capabilities.
APP fraud remains the industry’s most disruptive threat.
More than half (51%) identify APP fraud as a major operational challenge, making it the highest-ranked fraud risk.
Insider risk continues to demand attention.
78% have experienced insider fraud within the past year, highlighting the persistent challenge of internal threats.
Regulation is evolving faster than implementation guidance.
AI regulation and AML reform are jointly cited as the leading sources of regulatory uncertainty (19%), while 41% say AI governance lacks practical guidance.
AI governance has become a strategic capability gap.
Four in ten organisations (41%) say they lack the practical guidance needed to implement effective AI governance.
Organisations are investing in AI, but collaboration remains the missing capability.
Half plan to invest in AI fraud prevention, while just 32 respondents call for greater cross-industry data and intelligence sharing.
Industry implications
The survey findings suggest the financial crime landscape is entering a new phase. AI is increasing the speed and sophistication of fraud, while organisations are working to strengthen prevention capabilities, governance frameworks and operational resilience. Although investment is accelerating, many respondents believe regulation, implementation guidance and cross-industry collaboration are struggling to keep pace.
For organisations across UK financial services, the challenge is no longer simply identifying emerging threats, but responding to them effectively. Success will depend on combining technology investment with practical governance, effective intelligence sharing and stronger collaboration across the industry. The implications that follow consider what these findings mean for banks, fintechs, payment service providers, regulators and industry bodies.
Banks
Trust is being tested by scale
Digital identity/KYC weaknesses are felt most acutely here (63%, base: 40). Depth of existing controls matters more than speed of new adoption.
Fintechs
Fraud prevention is the sharper strain
Fraud prevention creates more operational uncertainty at fintechs than banks (38% vs 28%, base: 32 and 40). Scaling controls without legacy infrastructure is the harder build.
Payment service providers
Caught between two guidance gaps
PSPs sit at the overlap of AI governance and crypto compliance, the two areas rated least served by industry guidance. Clear standards here would unblock investment already underway.
Regulators and policymakers
The guidance gap is now the bottleneck
Firms are already spending against AI risk while the rules that should shape that spend are still forming. Investment is moving ahead of the guidance meant to direct it.
Methodology
Opinium surveyed 100 senior decision-makers in financial crime, fraud, risk, compliance and related functions at UK financial services organisations on behalf of The Payments Association, fieldwork 30 June-20 July 2026.