FIUs LACK RESOURCES AS FOCUS ON AML EFFECTIVENESS GROWS
December 5th, 2025Financial intelligence units (FIUs) may all have the same role to play under FATF guidance, notably its Recommendation 29 on FIUs, but these keystones of AML/CFT/CFP are far from equal, with resources varying greatly through government resources and policy.
FATF says FIUs must be a national centre for the receipt and analysis of suspicious transaction reports (STRs) and other information linked to ML, associated predicate offences and terrorist/proliferation financing, and disseminate that analysis. FIUs should be able to obtain additional information from obliged entities, and access relevant financial, administrative and law enforcement data.
These are heavy responsibilities, which apply to all FIU, and populous wealthy countries have the best resourced FIUs for delivering these goals. For instance, the USA’s FinCEN commands USD300 million in resources for the 2025 fiscal year (1), and around 300 employees, “mostly intelligence professionals, as well as specialists from the financial industry and computer experts”, said a note from the FIU. It also has around 20 long-term staff seconded from other regulatory and law enforcement agencies (2). While that might appear luxurious level of resources to some FIUs, when compared to FinCEN’s workload this financing appears tight – it means there were 14,687 suspicious activity reports (SARs) filed per staffer in 2024, or 40 per day, assuming no time-off, even for weekends (3).
Other countries generally have fewer resources – although they may be higher per head of population. In Canada (population 41 million, compared to the USA’s 340 million), the FIU Fintrac had a Canadian dollar CAD120 million (USD82.3 million) budget, employing 513 staff in 2023/4, according the the FIU’s 2024 annual report (4). With 631,137 SARs logged in Canada during 2023/24, that is 1,230 SARs filed per staffer, and 3.37 per day, a more manageable workload than their American brethren, according to official figures.
In Germany, staff numbers, according to its FIU’s last annual report (on 2023), are comparatively high – at 554 permanent employees, plus 200 seconded staff – no budget has been released by the FIU, which is part of the national customs administration. The FIU received 322,590 suspicious transaction reports (STRs) in 2023 – so 754 per employee – on paper a lighter burden than many FIUs, although Daniel Thelesklaf, the Head of FIU Germany, said in the report: “The year 2023 has been very demanding on my staff: The 116% increase in disseminated analysis reports compared to the previous year and the cases presented in this report demonstrate the prominent role that the FIU can take in preventing” ML and TF (5).
Small and developing states
Unsurprisingly, smaller jurisdictions have fewer resources – but they still must comply with FATF requirements or suffer during mutual evaluation reviews (MER). For instance, the UK-linked crown dependency of the Isle of Man has 25 staff and a budget of GBP1.22 million (USD1.64 million), according to its 2024/5 financial plan (6) handling 2,711 SARs in 2023/4 (7) – 108 per staff member annually. The Isle of Man’s workload is larger than many such small jurisdictions (its population is 84,160), because it is a financial and banking sector – comprising 48% of the economy, according to Finance Isle of Man, a government agency (8).
Another example is Antigua & Barbuda, whose population is 93,700, and which is a long-established centre for online gaming.
The Caribbean nation’s FIU is part of its Office of National Drug and Money Laundering Control Policy (ONDCP) which this year had a budget of USD2.4 million (Eastern Caribbean Dollars XCD6.59 million), the bulk being recurring expenditure, plus just USD171,000 capital expenditure). With a total of 69 staff, the body is woefully under resourced, admits ONDCP director Lieutenant Colonel Edward Croft. The complement includes two assistant directors, seven managers, 46 officers and two legal counsels. “We absolutely need more people,” he told MLB.
The Labour Party government did however cite beefing up the department with extra personnel as a “priority” in this year’s budget and pledged to embark on a recruitment drive.
As requirements from FATF increase and evolve “more is demanded of us”, Colonel Croft noted, “so we need more staff to keep up”.
Like much of the Caribbean, Antigua’s public sector remains heavily reliant on hard copy paperwork which hinders efficiency. Authorities have recognised the need for digitisation to better connect investigating agencies and speed up the sluggish pace of bringing financial criminals to justice.
This year’s budget also acknowledged the “dilapidated state” of offices used by law enforcement agencies, including the ONDCP, noting “infestation of termites, aged plumbing, and issues of mould”. Money was set aside to invest in air-conditioning to mitigate against the stifling climate, plus new computer software and hardware.
Recent figures were not available, but the ONDCP has typically dealt with hundreds of STRs a year, soaring from seven in 2000 to 253 by 2014. Causing particular headaches for Colonel Croft is cybercrime, which has seen an uptick in Antigua along with the rest of the world: “We need more investment in this area to allow us to address it,” he explains. “It poses particularly significant threats, not just in Antigua but everywhere.
“These cases are extremely expensive to investigate, and we need to strengthen our capabilities. When we work with international partners, their priorities are different to ours, which results in delayed responses to the public,” he told MLB, adding: “Using the scout motto, we need to be prepared.”
Larger countries facing government budget constraints have also seen FIUs suffering from resourcing pressures. A good example is Kenya (population 56 million), which was placed on the FATF grey list last February (2024). It was also this June (2025) placed under further scrutiny by the European Union (EU) listing it among 10 countries that have not fully addressed FATF listing concerns: “Kenya should therefore be considered a high-risk third country,” stated a European Commission briefing (9). Despite Kenya passing AML reforms via an Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act, 2025, which – for instance – adds precious metal and stone dealers as obliged entities – there is no indication that Kenya will exit the grey list soon (10).
John Kamau, a partner in charge of forensics and financial crime advisory at PwC Kenya, said that FATF was looking for effectiveness in implementing AML/CFT laws, including the performance of its FIU: “Legislation alone is not a silver bullet, as Kenya’s ability to exit the FATF grey list and the EU’s list of high-risk jurisdictions will hinge on how well these laws are implemented in practice,” Kamau told MLB.
But Kenya’s Financial Reporting Centre (FRC) faces severe funding restrictions, Saitoti Maika, the FIU’s director general, told MLB, warning it has been unable to increase its investigative staffing. Currently, the FRC’s overall approved establishment remains at 105 workers. Maika, in his financial statement (11) for the year ending June 30, 2023, noted that underfunding contributed to FRC failing to fulfil its mandate: “This led to delays and lowered quality outcomes as a result of trying to work with limited resources,” he noted.
For instance, whereas the Financial Reporting Centre (FRC), which is Kenya’s Financial Intelligence Unit( FIU), as per FATF regulations, is the primary investigator and receives reports on suspicious transactions related to the proceeds of crime, financing of terrorism, and money laundering, it has no prosecutorial powers, which are delegated to the directorate of public prosecutions and the police.
Indeed, the FRC’s budgetary allocation for that year was Kenyan Shillings KES585 million (USD4.5 million) – the most recent financial data made available.
Meanwhile, Kenya’s FIU’s workload has increased. In its 2024 annual report (12) released this March (2025), the FRC noted that banks and other credit institutions reported 94 transactions related to suspected terrorism financing last year (2024), compared to 72 cases in 2023; and financial institutions reported 7,193 suspected ML cases of money laundering last year, compared to 6,058 cases in 2023.
Ivy Momanyi, a senior associate, for forensics and financial crime advisory at PwC Kenya, said that while AML legislative reform was one step towards leaving the FATF grey list, “the work is far from over”.
Global under-resourcing
Under resourcing of FIUs worldwide is a common gripe, with only an estimated 4,500 full-time equivalent staff dedicated to financial analysis across all members of the Egmont Group of FIUs (now comprising 181 members), according to an annual report released in 2024, covering 2022 and 2023 data. That number, said the report, is “the same or less than the resources of the compliance department of ONE single global financial institution, underlining the critical issue of FIU resources”. (13)
John Cassara, a former US Treasury Special Agent, who worked at FinCEN for six years and an AML expert, thinks FinCEN, like other FIUs, need more human resources to process and analyse the huge number of SARs being filed.
“There are nearly 5 million SARs filed a year but count the number of FinCEN analysts – there’s maybe a dozen people that actually look through the SARs. If you divide 5 million by 12, and say OK, analyse them, that’s approximately 300 SARs an hour or five SARs a minute! FinCEN likes to say that ‘technology is our force multiplier’. Unfortunately, for over 30 years FinCEN has basically failed with developing and implementing the technology, and to efficiently and effectively analyse SARs and other forms of financial intelligence,” he told MLB.
That said, there is also a lack of follow up resources within law enforcement, he warned: “Yet even if we discount ‘defensive filings,’ if there was more robust technology, and FinCEN had more analysts to provide actionable information for authorities to act on, law enforcement doesn’t have the capacity to deal with them,” said Cassara.
He thinks a partial solution is for FIUs “to enter into a very active, ongoing and constructive dialogue with law enforcement. FIUs exist to support law enforcement. Some FIUs have moved away from that premise. They have become bureaucracies and sometimes more of a regulatory body. Instead of giving law enforcement volumes of data, law enforcement should tell FIUs specifically what they need to help them make cases. FIUs should tailor their work accordingly.”
Himamauli Das, senior managing director and counsel at New York-based global risk advisory K2 Integrity, and former acting director of FinCEN, said more resources are needed as “FinCEN is a lean institution”. He told MLB: “To achieve some of the objectives stated in the [USA] AML Act of 2020, requires resources and staff to carry that out. This is not an issue of just one simple fix. It requires a significant amount of dedication, effort, and people to improve the system, and for all stakeholders to communicate effectively,” he said.
While being under-resourced is a perennial issue for FIUs worldwide, better usage of data, using AI and machine learning, could lead to more effective use of SARs. “There are broad issues around FIUs having the resources they need to effectively analyse big data sets, combine SARs data with other data sets, such as transactional data or customs data, and deploy innovative technologies against those data sets to effectively leverage SARs for actionable activity. There is a need to dedicate resources to effectively using those tools,” said Das.
He suggested that FIUs can also use public-private partnerships to bring financial institutions and law enforcement together “to exchange operational information and deepen collaboration on the uses of innovative technologies, streamline data formats for more effective data analysis, share information on specific cases to assist compliance teams at financial institutions, and motivate sharing between financial institutions”. He told MLB: “Supervisors can play an important role in this process by providing incentives to financial institutions to participate in such partnerships and promote effective information exchange, by strengthening feedback loops, and by ensuring that their supervisory frameworks support the use of innovative technologies.”
NOTES
1 – https://home.treasury.gov/system/files/266/11.-FinCEN-FY-2026-CJ.pdf
2 – https://www.fincen.gov/frequently-asked-questions
3 – https://www.fincen.gov/sites/default/files/shared/FinCEN-Infographic-Public-2025-508.pdf
4 – https://fintrac-canafe.canada.ca/publications/ar/2024/1-eng
6 – https://www.gov.im/media/1382590/fiu_compressed.pdf
7 – https://www.fiu.im/media/1239/fiu-annual-report-23-24.pdf
8 – https://www.financeisleofman.com/sectors
9 – https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32025R1184
10 – https://new.kenyalaw.org/akn/ke/act/2025/6/eng@2025-06-20
13 – https://egmontgroup.org/wp-content/uploads/2024/07/2022-2023-Egmont-Group-Annual-Report.pdf
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