It is my pleasure to welcome readers to the 2025 ICC FraudNet Global Annual Report on Fraud and Asset Recovery. The ICC FraudNet Global Annual Report, now in its Fifth Edition, takes as its theme The State of Fraud and Asset Recovery: Timeless Crimes, Modern Approaches. It builds on the previous four editions of the Global Annual Report and expands ICC FraudNet’s growing body of thought-leadership, practitioner and scholarly insights.
While many readers are well acquainted with our work – for those unfamiliar, ICC FraudNet is the world’s leading fraud and asset recovery lawyers’ network with a membership spanning all corners of the globe. Members and Strategic Partners are routinely involved in some of the most high-profile, sensitive, complex and impactful fraud and asset recovery cases. Their perspectives in these pages make for fascinating and original reading.
Of course, 2025 as a backdrop to these contributions continues to present a world of challenges including conflict, economic hardship, political instability and social volatility. Financially acquisitive crimes like bribery, fraud, theft and money laundering continue to expand in scope and impact. The contributions in this Report endeavour to explain the incidence of such criminality, consider practical approaches within the law and investigations sectors to pursue, interdict and disrupt fraud and financial crime, while providing practical observations, expert insight and messages of caution to those interested in our field. The articles here provide expert observations on current and recent fraud cases, and thoughtful reflections on asset recovery investigations. From paper trails and ledgers, to learning models and dynamic technologies – the articles in this Report consider fraud and recovery from numerous approaches.
The themes and subjects addressed in this Report are vast and often overlapping, including: cyber-crime and ransomware attacks, corporate transparency and beneficial ownership information, looted state property and its recovery, crypto compliance, cyber-security challenges, foreign judgment enforcements, jurisdiction specific arbitration, trends in investigations such as Large Language Models, the impact of AI and AI-decision making in litigation and investigations, the relationship between equitable liens and fraud, exploration of different cash-tracing methodologies, the role and rationale of the financial regulator, offshore considerations, encrypted messaging applications and their challenges for investigators, recovering funds from complex banking chains, corruption and fraud, civil and criminal law mechanisms for asset recovery, and the manipulation risks presented by AI.
One of the resounding themes this year has certainly been the development of technology, its impact on fraud, its positive uses and negative risk-factors in terms of fraud as well as investigations, and warnings for future development, regulation and use. This is particularly visible in those papers which explore the increasingly potent role of AI – in some instances pointing to the pace at which it is simultaneously assisting fraud investigations, but also challenging them. Tales of caution about AI’s ability as a manipulator, as well as encouragement as to its helpful role in investigations, as well as its competence, or otherwise, in serving as a decisionmaker, are all considered in the Report.
As ever, jurisdiction representation in the Report is very strong – with original insights coming from leading lawyers and investigators in the U.K., U.S., Spain, Hungary, Ghana, Poland, Panama, Cayman Islands, New Zealand, Guernsey, Japan, the British Virgin Islands, China, Singapore and South Africa. The 23 original papers have been authored by some 37 authors.
Set against members’ and strategic partners’ busy workloads, our authors have, yet again, found time to write thought-provoking articles and thereby contribute their expertise to a wide readership through this publication. It is not only about showcasing the work that ICC FraudNet does as a network: but it is about contributing knowledge to important and ever-developing subject areas in which meaningful expertise is much needed. In an age of increasing content and soundbite knowledge; these papers represent thoroughly researched and thoughtfully considered approaches to important legal issues.
Since Covid-19, the relationship between volatility and fraud continues to be more relevant than ever. In the UK, as it is suspected in many other jurisdictions in which readers of this publication practise or live, fraud in today’s age is said to be the crime to which we are all most likely to fall victim. While keeping valuables out of sight of thieves has, perhaps, become common sense for many – fraud continues to perplex us for many reasons. It follows that if our understandings of fraud were so advanced, then surely it wouldn’t be the most likely crime we may fall victim to. As one author aptly notes in the coming pages, trust cannot be broken unless it is first given. As such, the stakes could not be higher.
The individually authored papers in this Report aim to offer practical and relevant perspectives on these important issues. Not only do we hope they are of use to the wider ICC FraudNet and ICC Networks, Strategic Partners and other professional collaborators, but also to clients and prospective clients. Further, it is hoped that the papers are of relevance to a wider audience including lawyers, investigators, enforcement and regulatory professionals, in-house compliance teams, policymakers and lawmakers, academicians and researchers alike. Ultimately, the papers draw upon collective and individual experiences, best practices and case studies seen at the cutting edge of the field. It is hoped that the compendium of papers offer real-world solutions and expert insights to tackle fraud and acquisitive misconduct, while offering support and practicality in terms of the challenges of international asset recovery efforts across different jurisdictions in responding to fraud. In doing so, the Report aims to support the reader’s understanding and knowledge in what is an increasingly complex subject.
It is hoped that the 2025 Report, like its previous editions, continues to serve as a useful research and practice resource for those interested in the field of asset recovery and fraud.
Dr Dominic Thomas-James
Editor, ICC FraudNet Global Annual Report
