Economic Crime Red Flags your Compliance Program should be watching in 2026

Two federal advisories and two global surveys published in 2026 point to the same three risk areas: payroll and labor-broker fraud, procurement fraud, and insider risk. Here's what each looks like in practice, and what a compliance program can check today.

1. Payroll and Labor-Broker Fraud

On June 5, 2026, FinCEN — jointly with the FDIC, OCC, NCUA, and IRS — issued Advisory FIN-2026-A002 on fraud schemes tied to unauthorized employment. The pattern shows up most often in agriculture, construction, domestic service, hospitality, and staffing, where employers use identity theft and off-the-books payroll to cut labor costs and evade payroll taxes.

What to check:

• Is an ITIN being used in place of an SSN for payroll-related accounts? FinCEN specifically flags this as a trigger for enhanced due diligence.
• Are labor-broker shell companies cashing checks and then redistributing funds in cash, by check, or through peer-to-peer platforms, after taking a 4–10% fee?
• If filing a SAR tied to this pattern, use the key term "FINANCIALINTEGRITY-2026-A002."

The scale is real: financial institutions flagged over $2.5 billion in suspicious activity tied to these schemes in 2025 alone.

2. Procurement Fraud

PwC's Global Economic Crime Survey 2024 ranks procurement fraud among the three most disruptive economic crimes of the past two years — behind only cybercrime and corruption. 55% of respondents call it a widespread concern, but most aren't using the tools available to catch it.

What to check:

• Does your procurement function use data analytics to flag anomalies? Nearly one in five organizations use none at all.
• Do you have a functioning third-party risk management program with actual risk scoring? 42% either don't have one or don't score within the one they have.
• If your organization sources from or through emerging markets or acquired businesses, has that exposure been reassessed recently? PwC flags both as drivers of rising complexity.

3. Insider Risk

A separate PwC survey — Insider Risk: Client Survey Insights 2026, fielded December 2025–February 2026 — found insider risk evolving faster than most organizations' ability to respond to it.

What to check:

• Do you have a named owner for insider risk? 13% of organizations currently don't.
• Has a holistic insider risk assessment been completed in the past 12 months? Only 40% can say yes.
• Are access controls and monitoring keeping pace with AI-related exposure? No organization surveyed felt very well prepared for AI-driven insider risk, and 40% called themselves only minimally prepared.

One-third of organizations reported an actual insider-related incident in the past year. 60% now treat it as a board-level issue — but only 27% are very confident they could detect and respond to one.

The Takeaway

None of this is abstract risk. It's the specific pattern regulators and global survey data are both pointing to right now: identity-based payroll fraud, under-monitored procurement, and insider risk that's outrunning oversight. A program that matches the industry average on any of these three may not be an adequate program — the industry average, by its own numbers, is under-prepared.

Sources: FinCEN Advisory FIN-2026-A002 (June 5, 2026); PwC Global Economic Crime Survey 2024; PwC Insider Risk: Client Survey Insights 2026.