Customer risk assessment: navigating the AML/CFT risks of social media influencers

Jun 11 / Leonard Nwogu-Ikojo
The rise of the influencer economy is transforming how money moves across digital platforms—and how compliance teams must respond. As content creators increasingly earn income through sponsorships, donations, crypto, and affiliate marketing, they are becoming active participants in the regulated financial system. Yet with opaque income streams, cross-border activity, and ties to high-risk sectors like gambling or unlicensed finance, influencers present unique AML/CFT challenges. Under the EU’s evolving regulatory landscape, institutions must now treat them as a distinct client category—applying enhanced due diligence, behavioural monitoring, and reputational screening to balance innovation with financial integrity.

The rise of the influencer economy

The global influencer economy is now a multibillion-euro sector, driving consumer behaviour across industries—from fashion and gaming to finance and crypto. As influencers monetise their platforms through sponsorships, fan donations, affiliate marketing, and even personal fundraising, they increasingly engage with the regulated financial system.

However, this new client segment presents emerging money laundering and reputational risks. Financial institutions, fintech firms, and crowdfunding platforms must now evaluate influencers within their Customer Risk Assessment (CRA) frameworks, applying appropriate due diligence and monitoring measures.

Why influencers pose AML/CFT risk

While most influencers are legitimate entrepreneurs, several structural characteristics make them a non-traditional but potentially high-risk category under AML/CFT frameworks:

1. High-volume, low-transparency revenue

Influencers often receive income from diverse, opaque sources such as:

  • Sponsorship payments via digital wallets or unregulated platforms
  • Crypto-based donations from anonymous fans
  • Monetised livestreams or in-app tipping (TikTok, Twitch, YouTube)

2. Use of informal or opaque financial channels

Many influencers operate across jurisdictions and may use:

  • Unregulated or opaque informal agents (e.g., brand managers, virtual assistants operating without clear mandates)
  • Third-party accounts or corporate structures (including newly formed entities or shell companies lacking clear legitimate business purpose) for payments
  • Virtual assets (NFTs, tokens) with limited traceability

3. Association with high-risk sectors or activities

Some influencers promote or engage in:

  • Online gambling, forex and crypto schemes (especially those promising unrealistic returns or lacking regulatory oversight)
  • Controversial or adult content (e.g., OnlyFans, camming)
  • Political activism or fundraising linked to sanctioned entities, illicit activities, or in high-risk/sensitive jurisdictions

Both the UK's FCA and France's AMF have been highly active in 2024 and 2025, issuing warnings, taking enforcement actions, and launching criminal proceedings against "finfluencers" promoting unauthorized and often fraudulent investment schemes, including those linked to pump-and-dump scams and Ponzi structures, highlighting an ongoing global regulatory effort to curb such illicit financial promotions on social media.

Institutions onboarding influencers must consider both financial and behavioural red flags—including online conduct, political affiliations, and cross-border activity.

Customer risk assessment factors for influencers

When assessing influencer clients, institutions should consider using a multi-dimensional risk lens, covering source of funds, jurisdictional risk, transactional behavior, reputational risk, channel type, and any other relevant risk factor.

Possible red flags to watch

Compliance teams should train staff to detect the following red flags when onboarding or monitoring influencer accounts:

  • Frequent crypto-fiat conversions without a clear, legitimate business case
  • Payments from multiple unrelated jurisdictions, especially high-risk ones
  • Use of opaque offshore entities or nominee accounts lacking clear beneficial ownership or legitimate purpose
  • Receipt of donations from pseudonymous wallets or unverifiable sources
  • Sudden significant spikes in account activity following a viral campaign or controversy, disproportionate to declared business activity
  • Promotion of unregulated or suspicious investment schemes, gambling, or illicit content

Helpful practices for managing influencer risk

To mitigate risk while supporting innovation and legitimate business, institutions can:

Enhance due diligence

  • Require additional documentation on income streams, detailed business models, and contracts (e.g., with platforms, brands, or agencies).
  • Perform thorough public domain checks (e.g., content on Instagram, YouTube, TikTok, Patreon) to understand content, audience, and potential controversies.

Establish risk scoring for creators

  • Develop tailored customer risk scoring methodologies specifically for digital content creators and influencers.
  • Automate alerts tied to high-risk keywords in content, or sudden, unexplained payment pattern shifts.

Monitor third-party payments

  • Watch for frequent payments from shell companies, complex corporate structures, agents, or unverified crypto exchanges.
  • Apply the Travel Rule for VASP-related transfers where applicable.

Integrate reputational monitoring

  • Leverage advanced OSINT and adverse media monitoring tools to identify real-time controversies, legal risks, or negative news.
  • Cross-check with sanctions, PEP, and adverse media lists consistently.

Be prepared, not reactive

Influencers are reshaping the way individuals earn, transact, and invest. As the influencer economy matures, regulated institutions must ensure their customer risk assessments reflect the complexities of digital-first business models.

A risk-based, adaptive compliance approach—grounded in behavioural analysis and real-time media monitoring—can help firms manage exposure while enabling responsible financial inclusion.

Resources and Guidance

  • EU AMLR – Regulation (EU) 2024/1624 (Anticipated framework)
  • FATF Guidance on New Technologies (2023 onwards)
  • EBA Risk-Based Supervision Guidelines (Ongoing updates)
  • FCA Warning List on Financial Influencers
  • AMF France: L'influence financière sur les réseaux sociaux
  • FCA Press Release: "Finfluencers' charged for promoting unauthorised trading scheme" (May/July 2024).
  • FCA Press Release: "FCA leads international crackdown on illegal finfluencers" (June 6, 2025).
  • FCA: "Financial promotions data 2024" (February 7, 2025).
  • Finance Magnates: "French AMF Shuts Down 181 Fraud Investment Sites in 2024 as Losses Hit Almost €30K per Victim" (May 26, 2025).
  • AMF News Release: "The AMF and the ARPP launch the Responsible Influence Certificate in Finance" (June 20, 2025).
  • AMF News Release (republished by FSMA): "The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so" (April 4, 2024).



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