Risk, Regulation, and Resilience: The 2025 Compliance Playbook

Emmy Richardson

By Emmy Richardson
Senior Compliance Associate, LBMA

As we enter 2025, geopolitical shifts, economic volatility, regulatory developments, and rapid technological advancements are reshaping the precious metals industry. Market participants must balance responding to new and emerging risks — such as financial crime, digitalisation, and evolving sanctions regimes — while maintaining the integrity of business-as-usual (BAU) compliance functions.

In this environment, agility and adaptability are more critical than ever. Illicit actors are becoming increasingly sophisticated in their exploitation of the market, leveraging complex networks to bypass regulatory scrutiny. Meanwhile, digital innovations such as AI and tokenisation present both opportunities and compliance challenges. At the same time, global regulatory expectations are shifting, particularly as new governments take office and refine their priorities.

The industry’s response to these challenges will define its ability to maintain market integrity. While firms must prepare for the future, they cannot afford to neglect the fundamentals. This article explores three key compliance themes that will shape the year ahead: the increasing risks of financial crime, navigating uncertainty, and the importance of maintaining strong BAU compliance frameworks.

1. Follow the Money: The Acceleration of Financial Crime and AML Risks

As the gold price continues to chase new highs, the precious metals market faces heightened exposure to financial crime. The allure of gold’s liquidity, portability, and intrinsic value has long made it an attractive asset for illicit actors. However, in 2025, the sophistication of financial crime is accelerating at an unprecedented rate, fuelled by technological advancements, economic uncertainty, and increasingly complex global supply chains.

Organised Crime and Illicit Gold Flows: A Growing Threat

One of the most concerning trends in 2025 is the increasing role of organised crime in legitimate markets, particularly within the gold supply chain. Surging demand for gold has widened the gap between licit supply and market appetite, creating opportunities for illicit actors to fill the void. Unregulated gold mining, smuggling, and fraud schemes linked to high-value commodity transactions are likely to be more prevalent.

Organised crime remains the primary driver of financial and economic crime globally. Addressing this challenge requires a proactive, intelligence-led approach from both regulators and businesses. LBMA’s Responsible Gold Guidance (RGG) has played a key role in setting global sourcing standards for refiners, but all market participants — traders, vault operators, and financial institutions — must assess their exposure to criminal networks. This means shifting from a ‘tick-box’ compliance mentality to dynamic risk management, leveraging technology to gain deeper insights into supply chain vulnerabilities.

Regulatory Pressure and Market Expectations

The convergence of fraud and anti-money laundering (AML) risks presents one of the most pressing challenges for market participants navigating compliance in the year ahead. Traditionally, fraud detection and AML compliance have been treated as separate disciplines, but regulators are increasingly viewing them as interconnected threats.

Criminal networks are leveraging advancements in artificial intelligence (AI), automation, and decentralised financial technologies to execute more sophisticated schemes, exploiting gaps in compliance frameworks. As a result, financial crime oversight is tightening. Governments and regulators worldwide — including the UK’s Financial Conduct Authority (FCA) and the US Department of the Treasury — are intensifying enforcement action, expanding their focus beyond traditional AML measures to tackle fraud, sanctions evasion, bribery, and corruption.

For precious metals firms, this means compliance must evolve beyond static risk assessments to agile, technology-driven approaches that can detect and respond to threats in real time.

Technology and the Future of Financial Crime Compliance

The fight against financial crime in 2025 will be defined by the role of technology. As fraud and AML risks evolve, so too must the compliance tools used to detect and mitigate them. Key trends shaping financial crime prevention this year include:

  1. Real-Time Monitoring: As financial institutions transition toward real-time transaction monitoring and cloud-based fraud detection, corporates must also enhance their surveillance capabilities to keep pace with evolving threats.
  2. AI and Machine Learning for Risk Analysis: AI-driven analytics are moving beyond Tier 1 banks, increasingly being adopted by mid-sized institutions and multinational corporations to improve data structuring and predictive risk modelling.
  3. Automation in Investigations: With fraud cases rising, firms cannot rely solely on human investigators. Automated fraud detection and AI-driven investigation tools will become critical in reducing the burden on compliance teams.

As firms adopt multi-layered detection strategies, combining transaction monitoring, payment screening, human-led investigations, and name screening, one thing is clear: complacency is not an option. In 2025, financial crime is more sophisticated and complex than ever before. Staying ahead of emerging threats requires continuous investment in compliance infrastructure, an openness to new technologies, and a willingness to recalibrate risk frameworks in response to an ever-evolving regulatory and criminal landscape.

In 2025, the sophistication of financial crime is accelerating at an unprecedented rate, fuelled by technological advancements, economic uncertainty, and increasingly complex global supply chains.

2. Embracing the Unknown: Agility as a Strategic Imperative

The year ahead brings with it a wave of uncertainty: geopolitical shifts, economic volatility, rapid technological advancements, and evolving regulatory landscapes. With significant changes in government leadership expected across multiple jurisdictions, regulatory priorities and enforcement approaches may shift, bringing new challenges and opportunities for the precious metals industry.

To navigate this environment, agility and adaptability must become strategic imperatives.

Navigating Political and Regulatory Uncertainty

The precious metals industry has long operated at the intersection of finance, trade, and policy, meaning it is particularly exposed to changes in global governance. The outcomes of elections in major economies could impact everything from sanctions regimes and AML regulations to environmental and supply chain due diligence requirements.

While regulatory uncertainty can feel like a moving target, firms that remain engaged, informed, and adaptable will be able to anticipate and respond effectively to change. This means:

  • Preparing for shifting compliance expectations, including new regulations covering financial crime, ESG, and digital assets.
  • Monitoring evolving trade policies, as new tariffs or restrictions could alter supply chain dynamics and the movement of gold.

To navigate this environment, agility and adaptability must become strategic imperatives.

3. Business as Usual: Strengthening Core Compliance Functions Amid Change

While firms must prepare for an evolving regulatory landscape, strong BAU compliance functions remain essential. A proactive approach to compliance means ensuring that core frameworks — including risk monitoring, governance, and training — are robust enough to withstand new challenges.

Market participants should focus on:

  1. Keeping Pace with Emerging Risks by regularly updating policies, procedures, and systems.
  2. Adopting a Dynamic, Data-Driven Approach to Risk Assessment by incorporating new risks such as AI-driven fraud and cyber threats.
  3. Building Compliance Awareness Across the Business by investing in role-specific training, real-world case studies, and a culture where compliance is embedded in decision-making.
  4. Strengthening Accountability at the Leadership Level, ensuring boards understand key compliance risks and allocate sufficient resources to manage them effectively.

A proactive approach to compliance means ensuring that core frameworks are robust enough to withstand new challenges.

A Defining Year for Compliance

2025 will be a defining year for compliance in the precious metals industry. Firms that treat compliance as a strategic asset rather than a regulatory burden will be best positioned to navigate uncertainty, maintain trust, and uphold market integrity.

By embracing technology-driven compliance, proactive risk management, and strong governance, market participants can turn disruption into an opportunity — one that strengthens resilience, enhances reputation, and safeguards the industry’s future.

Stay Compliant

Stay compliant and sharpen your market expertise! Enrol in LBMA & ACI’s online Global Precious Metals Code training today. Contact training@lbma.org.uk to sign up.

Emmy Richardson

By Emmy Richardson
Senior Compliance Associate, LBMA

Emmy works alongside the Membership, Good Delivery and Responsible Sourcing departments to manage and develop the compliance programme across the spectrum of LBMA's work. Emmy also supports market development projects with a focus on data and analytics.