Beyond Compliance: Enabling the Next Generation of AI Technology to Dismantle Illicit Liquidity Networks

Inside the Shadow Architecture That Shapes Modern Conflict

Primer: How This Piece Got Here

This essay has already lived a small life of its own.

Since July, it circulated through several major legacy outlets. Some passed quickly and professionally; others expressed enthusiasm, requested time-consuming revisions, and ultimately stepped back for reasons that were never fully articulated. The responses varied, but the pattern was clear: uncertainty around unfamiliar frameworks, discomfort with material that sits outside conventional editorial lanes, and a broader hesitancy to publish work that challenges inherited assumptions.

The experience reinforced something that is only now beginning to shift. As recently as this past summer, traditional media still treated illicit liquidity as a peripheral issue. But the field is finally catching up. The traction my newer work has gained—across policy, enforcement, and analytical circles—reflects a broader recognition that liquidity is central terrain, not an auxiliary concern. The industry is evolving, even if the legacy editorial machinery has been slower to recognize the shift.

This piece was written to explain that evolution—how illicit liquidity systems now outlast militaries, sanctions regimes, and enforcement architecture itself—and why understanding this shift is no longer optional. Its publication journey ended up mirroring its own thesis: frameworks built for a previous era often struggle to accommodate the realities of the present one.

Since writing it, I’ve expanded and refined many of the concepts it introduced, but this remains the originating document. I am publishing it here in the form it was meant to take—not diluted, not retrofitted to an older template, and not reshaped to fit the boundaries of legacy formats. If those outlets revisit this space later, they can. My readers don’t need them to recognize the stakes.

Below is the full piece, unchanged except for minor clarity edits—the version that wasn’t designed to make anyone comfortable, but to make the problem clear.

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In May 2025, FinCEN designated Huione Group and Huione Pay as a “primary money laundering concern”, citing $4 billion in proceeds tied to scams, human trafficking, and North Korean hackers. Despite global scrutiny, Huione remains operational.

This outcome is a strategic warning.

Huione’s resilience typifies a new global architecture of shadow liquidity that sustains conflict, corruption, and authoritarian influence from Southeast Asia to West Africa and beyond. These networks do not survive because they evade detection but because enforcement strategies continue to treat financial infrastructure as peripheral rather than primary terrain.

While U.S. and allied responses have prioritized weapons transfers, territorial control, and traditional alliance-building, adversaries have quietly focused on what actually sustains power: value mobility. The real vulnerability is our failure to treat financial infrastructure as battlespace—one that sustains adversaries and keeps them resilient against sanctions and other enforcement measures.

If adversaries can move value with speed, deniability, and scale, they do not need air superiority or territorial control. They can fund insurgency, project influence, and exploit crises faster than formal systems can adapt. The longer this architecture remains intact, the greater the threat to global stability.

To remain effective, national security thinking must evolve to treat financial infrastructure as core battlespace. This includes conceptualizing the purpose of tools currently under development, such as DARPA’s Advanced Analysis of Multinational Money Laundering (A3ML) initiative—not merely as forensic engines, but as platforms for pre-emptive disruption of shadow liquidity networks.