AML in Card Networks, Roundtable hosted jointly by Brighter Consultancy and Mastercard

Brighter Consultancy and Mastercard convened the first in a series of Roundtable events focused on AML and Fraud, at Mastercard’s London Angel Lane offices on Tuesday 15^th September.

We are sharing a short blog series update for those who were unable to attend the inaugural event, but please reach out to Alfie Harris to register your interest to be included in the invitations for the next event.

Simon Davis, Chairman at Brighter Consultancy, opened the session with insights around the emerging risks being seen in card rails.

These included the impacts of AI both for organised crime gangs and institutions tasked with mitigating financial crime risk (incredibly topical right now), money mules, merchant/processor transactions and/or account abuse, “nested risks”, pre-paid cards and wallets, wallet connections to crypto and instant payment ecosystems, speed of organised crime gang mobilisation, and convergence/interlinking of fraud and AML.

The process is becoming more complex and nuanced:

1. Criminal proceeds
2. Mule/compromised identity
3. Card/account
4. Merchant/processor
5. Wallet/fintech
6. Another payment rail
7. Crypto/offshore account
8. Cash-out

While dodgy individual card transactions are becoming harder to distinguish from legitimate commerce, the signal increasingly sits in the relationships between transactions and what can be seen in network-wide data.

We talked about the importance of:

1. Entity resolution: identifying when apparently separate customers, cards, devices, merchants and accounts are actually connected.
2. Graph analytics: detecting clusters and money-flow networks rather than isolated transactions.
3. Behavioural monitoring: understanding what “normal” looks like for a cardholder, merchant and processor.
4. Cross-rail visibility: connecting card activity with bank transfers, wallets, cash, crypto and other payment mechanisms.
5. Real-time intervention: detecting suspicious activity before settlement or onward movement where possible.
6. Merchant-level intelligence: validating that transaction activity makes economic sense for the merchant's actual business.
7. Mule detection: identifying accounts/cards that are functioning as pass-through nodes rather than genuine consumer accounts.

Sitting across all of these is network-level data, rather than enterprise-level data... and that is something that Brighter Consultancy and Mastercard together can bring to the table for financial services businesses struggling to meet the evolving activity from organised crime.

For more information, a conversation, or just to catch up on the emerging issues, please reach out to either @alfieharris or @darrentemple to arrange a confidential chat.

The Strategic Takeaway

Card rails themselves aren't necessarily becoming inherently “dirtier.” They're becoming a more attractive component of sophisticated laundering chains.