September 30, 2026 - At the American Bar Association International Law Conference in London last week, Ian Casewell joined Carmen L., Xuanhan (Alisha) L., and program chair Joseph Rome for a discussion on Informal Financial Networks, Corruption Risk & Cross-Border Enforcement Strategies. The panel explored the prevalence of underground banking and how citizens, companies, corrupt actors, and criminal groups rely upon informal financial networks to move vast sums of money around the world. We discussed trends in Asia, how these networks operate, strategies to investigate and counter them, and recent developments in the UK and US.
From whichever jurisdiction you view the trend, it has grown significantly over the past decade. Many governments see these networks fueling large-scale capital flight, tax and sanctions evasion, money laundering, and the growth of organized crime. As money moves outside the traditional banking sector, investigations become more demanding and complex because it is harder to track and trace the movement of funds. Commercial banks function as the frontline in detecting underground banking behavior and defending against illegal value transfers.
A recent criminal case in Belgium offered a striking snapshot into one such network. Prosecutors examined a WhatsApp channel entitled “The Traders of Greater Europe," where 532 hawaladars exchanged more than 82,000 messages offering and requesting money transfers. Over the course of only a few months, investigators observed hundreds of millions of euros in cash movements, much of it linked to terrorist financing, people trafficking, and other forms of organized criminality.
Thank you to our fellow panelists for a fascinating discussion on a challenge that continues to evolve in scale, complexity, and global impact.