The issue of supply chain due diligence is at the forefront of the corporate agenda as more and more companies suffer financial and reputational damage as a result of their failure to conduct such due diligence effectively. These risks were highlighted in July 2021 when it was reported that Inditex, the parent company of Zara, and Sketchers were profiting from forced labour by sourcing clothing from factories in China where Uyghurs were interned (see Figure 1). Recognising the financial and reputational damage that these reports could cause, both Inditex and Sketchers released statements reiterating their zero-tolerance policy on forced labour.
Figure 1: A Themis Search investigation detailing adverse media surrounding Inditex SA following reports that they sourced clothing from factories where forced labour was used.
In February 2022, the European Commission announced that it had adopted a proposal for a Corporate Sustainability Due Diligence Directive (CSDDD). The CSDDD, which is expected to pass into law by the end of this year, is underpinned by a growing desire to foster responsible and sustainable corporate behaviour among companies. While a number of the EU’s Member States have already introduced similar legislation domestically, as seen in France with the Loi sur le Devoir de Vigilance, the EU has adopted the CSDDD to reduce reliance on unstandardized voluntary action. The CSDDD focuses on the following companies:
and requires them to:
The CSDDD’s emphasis on appropriate measures and due diligence should therefore lead to more comprehensive efforts from companies to mitigate and prevent adverse human rights and environmental impacts across their supply chain. This should also reduce the incidence of associated financial crimes, namely environmental and wildlife crime and modern slavery and human trafficking (MSHT), as more rigorous checks by companies leave criminals with far less room than they currently have to profit from such crimes.
Companies may suffer financial loss if they fail to adhere to the directive as national administrative bodies can penalise them with financial penalties; those who fall victim to damage that could have been avoided with proper due diligence will also be able to launch civil claims against companies. Significantly, such cases invariably lead to reputational damage. The CSDDD has a broad scope by virtue of the fact that it applies to an eligible company’s subsidiaries and value chains in addition to their own operations. As a result, the CSDDD has been heralded for ensuring that governance frameworks give adequate attention to environmental and social risks in their decision-making as well as the externalities of these decisions.
While the CSDDD appears to be a momentous development at first sight, it has been reported that the Council of the European Union has currently agreed to exclude banks and investment funds from the directive. This would be a significant omission given that financial institutions lie at the heart of combating the likes of MSHT, enabling the flow of associated illicit funds. In addition, the effectiveness of the CSDDD is hindered further by its narrow scope; while small and medium-sized businesses (SMEs) may be affected indirectly by virtue of their involvement in a larger company’s supply chain, it does not apply to SMEs despite this group accounting for 99% of the companies in the EU.
If the imminent passage of the CSDDD into law has you concerned about the risks that your business may be exposed to, the Themis Supplier Risk Assessment can put you at ease. This newly released tool helps you identify and assess the specific financial crime threats your business is exposed to through your suppliers and third parties. Having your suppliers and other third party stakeholders complete the diagnostic will enable you to understand which of them represents the greatest financial crime risk to your business and in which area, be it in their governance framework and/or controls to mitigate specific financial crime risks, including modern slavery.
Themis’ Anti-Slavery Hub also provides complimentary guidance to financial institutions on the ways they can identify and tackle modern slavery and human trafficking by providing an array of resources, including digital learning and red flags. The Illegal Wildlife Trade Toolkit, meanwhile, mirrors this by providing financial institutions with free guidance on the ways they can identify illicit funds linked to the trade among other things.
If you would like to read further about the issue of supply chain due diligence, we’ve recently released a briefing note, No Firm is an Island: The Importance of Supply Chain Due Diligence, which you can read here.
Stay on top of the ever-changing financial crime landscape by accessing the latest information on emerging criminal techniques and the risks associated with carrying out business with particular industries or in particular jurisdictions.
Significant updates to the Land Conversion and Financial Crime Risk Assessment highlight links between environmental harm and financial crime. Cattle rustling in Nigeria and Cameroon now carries a red risk rating. Other updates cover carbon credit fraud, child labour, corruption in mining, and gold smuggling. A new toolkit search aids detection.
An overview of modern slavery, distinguishing between human trafficking, smuggling, and forced labor. It highlights the global prevalence of exploitation and the importance of understanding these definitions to combat such crimes.
Dubai’s booming real estate market, with over $160 billion in foreign ownership, is vulnerable to financial crimes like money laundering. The UAE now requires real estate professionals to report high-value transactions over AED 55,000 through the Real Estate Activity Report (REAR). Criminals, such as Daniel Kinahan, have exploited property investments to hide illicit funds. The article urges strict compliance and awareness to enhance financial transparency and prevent abuse within the sector.
Examines how digital platforms and cryptocurrencies facilitate human trafficking, allowing traffickers to operate anonymously and at scale, posing challenges for law enforcement.
Investigates how sanctions intersect with trade-based financial crimes in Hong Kong, highlighting the complexities businesses face in navigating regulatory compliance.
Financial crimes cause more than economic damage—they deeply affect mental health. A UK survey found 60% of fraud victims experienced emotional distress, with many reporting panic attacks and weight changes. In Ghana, exposure to corruption correlated with anxiety and depression in young adults. The blog calls for greater recognition of these hidden harms and urges a more empathetic approach to tackling financial crime, emphasizing both psychological and financial well-being.
Environmental crime disproportionately impacts women, worsening existing gender inequalities. Illegal logging and mining fuel gender-based violence and trafficking, especially in regions like the DRC and Peru. Women environmental defenders face targeted abuse, while climate change increases hardships for women reliant on natural resources. Consequences include water scarcity, child marriage, and health risks from extreme heat. Tackling environmental crime is essential for protecting women’s rights, safety, and health in vulnerable communities.
AI is transforming financial crime prevention by enhancing detection, streamlining compliance, and lowering costs. The blog highlights how generative AI and tools like graph neural networks improve due diligence and empower institutions. While criminals exploit AI for fraud, its ethical use—combined with human oversight—can democratise compliance and boost resilience. Themis advocates for embracing AI’s potential to fight financial crime effectively, focusing on collaboration between technology and human expertise.
Explores the application of fuzzy logic in Anti-Money Laundering (AML) systems, emphasising its role in improving name-matching accuracy and reducing false positives, thereby enhancing compliance efficiency.
This book focusses on the challenges faced by law enforcement in North West USA and in British Columbia to combat illegal logging, as well as those of the timber-industry communities established since the late 19th century to maintain meaningful and financially viable lives.
Lebanon’s economic collapse—driven by debt, corruption, and political instability—has led to hyperinflation and a reliance on cash, increasing exposure to financial crime. In October 2024, the FATF added Lebanon to its grey list for failing to meet anti-money laundering and counter-terrorism financing standards. This listing hinders foreign investment and remittances. In response, Lebanon has pledged a two-year reform plan to improve financial transparency and rebuild international confidence.
The UK treats proceeds from foreign cannabis businesses as criminal property under the Proceeds of Crime Act, even if earned legally abroad. Despite exceptions for overseas conduct, cannabis-related activities typically exceed the 12-month sentencing threshold, making them ineligible. This legal grey area has prompted calls for reform. Until clarified, businesses and individuals handling foreign cannabis funds in the UK should act cautiously and seek legal guidance to avoid potential money laundering risks.
The UK’s 2023–2026 Economic Crime Plan commits £400 million to tackling financial crime, focusing on reducing money laundering, combating kleptocracy, and tackling fraud. It includes reforms to Companies House, cryptoasset regulation, sanctions enforcement, and fraud prevention. While progress has been made since 2019, challenges remain. Critics argue the plan lacks funding and urgency, but success depends on collaboration across government, private sector, and individuals to stop illicit finance and protect society.
Emphasising the critical role of Suspicious Activity Reports (SARs) in combating financial crime. It advocates for fostering a culture of transparency within organisations, encouraging employees to report suspicious activities without fear of retaliation. Highlighting that 42% of fraud cases are detected through tip-offs, the article underscores the importance of internal reporting mechanisms. It also notes a significant increase in SARs and associated account freezes in the UK, demonstrating their effectiveness in disrupting illicit financial activities.
Corrupt elites continue exploiting the UK property market, using offshore structures and relatives to hide assets. Despite the 2022 Register of Overseas Entities, over 18,000 companies failed to comply or obscured ownership. Cases involving Russian and Azerbaijani figures reveal children owning multimillion-pound properties. Themis warns of widespread misuse of family ties and urges stronger enforcement. Updated FATF guidance and UK regulations aim to close transparency gaps and tackle hidden financial crime risks.
Corruption undermines sustainable development and fuels financial crimes, while also impeding diversity, equity, and inclusion (DEI). A joint analysis by Themis and Denominator found a strong inverse correlation: countries with lower corruption levels have higher DEI scores. Corruption disproportionately harms marginalised groups, especially women. Increasing diversity in leadership helps disrupt corrupt networks, though true progress requires democratic values, transparency, and inclusion. Emphasising DEI is crucial for combating corruption and promoting fair, inclusive societies.
A report by Hindenburg Research accuses India’s Adani Group of major corporate fraud, alleging stock manipulation, shell companies, and nepotism. The claims have halved Gautam Adani’s net worth and shaken investor confidence. Adani’s political ties raise concerns over cronyism in India. The scandal underscores the impact of financial crime on markets and highlights the critical need for robust due diligence to detect risks early and preserve economic integrity and transparency.
Corporate failures in supply chain due diligence have led to financial and reputational damage, with cases like Inditex and Sketchers linked to forced labour. The EU’s upcoming Corporate Sustainability Due Diligence Directive (CSDDD) will mandate large companies to address human rights and environmental risks across operations and supply chains. While promising, the directive excludes financial institutions and SMEs, limiting impact. Themis offers tools to assess supplier risk and fight crimes like modern slavery.
On World Wildlife Day and CITES’ 50th anniversary, Themis reflects on the global fight against illegal wildlife trade (IWT), the world’s fourth most lucrative financial crime. Peru’s recent legislation classifying IWT as organised crime marks major progress, but tougher ivory bans have shifted demand to hippo teeth, threatening new species. Despite setbacks, forensic science, AI, and volunteer cyber-spotters are enhancing detection and prosecution, proving that innovation and global cooperation can counter IWT effectively.
Puppy smuggling in the UK has surged post-pandemic due to soaring demand and prices, making it a target for organised crime. Criminals exploit legal loopholes, importing underage, sick, or pregnant dogs under non-commercial regulations. Despite new legislation, weak enforcement and lack of visual checks persist. Case studies reveal networks laundering money through illicit breeding. Buyers must remain vigilant, and due diligence—like using Themis Search—can help uncover breeder criminal links and protect animal welfare.
Romance scams rose by 30% in 2022, with victims losing an average of £8,234—especially impacting men and those aged 65–74. Scammers exploit dating apps and social media, using fake profiles and emotional manipulation to defraud victims. Themis urges individuals to conduct due diligence in dating, just as in business. Tools like Themis Search can uncover red flags, helping users avoid fraud and enabling dating platforms to protect users more effectively.
With crypto’s volatility and under-regulation under renewed scrutiny, its dual role in social good and financial crime is clear. While over $50 million in crypto has supported Ukraine, scammers and sanctioned actors also exploit it. Russia’s use of crypto to bypass sanctions, particularly via the UAE and the Central African Republic, raises serious concerns. Themis urges enhanced due diligence, sanctions screening, and compliance to mitigate crypto’s abuse in fraud, laundering, and geopolitical manipulation.
How the Russian invasion of Ukraine has exacerbated human trafficking risks, particularly for women and children. With over 2.5 million people fleeing Ukraine, traffickers exploit the chaos, offering false promises of shelter or work. Existing trafficking networks in Eastern Europe, especially in Moldova, Poland, and Italy, capitalize on the lack of coordination at border crossings. The OSCE recommends immediate measures to inform refugees about potential risks and deceptive offers.
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