fictitious profiles and even bot accounts. Some dating services operate across jurisdictions, particularly in niche markets, e. g., international matchmaking or expat dating, which, in the absence of adequate CDD and fraud controls, allow for misuse of services and potential sanctions exposure.
Furthermore, some online dating platforms allow users to send virtual gifts to live streamers. Streamers can convert gifts into real money, typically via payment mechanisms supported by the platform. 26 The monetization model enables users to potentially“ make big bucks.” 27 But, it does raise concerns about pseudo-anonymous value transfers, especially absent redemption thresholds or controls to verify user identity, prevent otherwise prohibited cross-border transactions or limit the use of multiple accounts.
Regulatory and LE efforts
FinCEN issued advisories to warn against dating shams linked to money laundering, romance scams and pig butchering throughout recent years. 28 Similarly, the FBI has issued public warnings and regularly distributes educational content via its website and podcast. 29
The Federal Trade Commission( FTC) also plays an important role in the dating industry, publishing data on romance scam trends and consumer losses and investigating deceptive practices by numerous mainstream players dating back as early as 2013. 30, 31 The FTC would also be responsible for enforcing requirements under the proposed Romance Scam Prevention Act, if passed; the Act is intended to address online dating fraud, requiring platforms to inform users who interacted with other users who were ultimately banned 32
In addition, in February 2025, the Commodity Futures Trading Commission launched the“ Dating or Defrauding?” initiative, a nationwide effort between federal and state regulators and nonprofit organizations to raise awareness about romance investment scams. 33
These are meaningful ― although ad hoc ― advancements. The industry could benefit from structured oversight to legitimize the space and invite collaboration with external partners.
Bridging the gap ― Avenues for FIs
With dating services on the rise, FIs in the mainstream payment space are presented with more opportunities to engage with the industry.
1. Seek assurances
Most FIs take a tiered approach to onboarding. When considering high-risk verticals, they often require clients complete specialized due diligence( SPDD) questionnaires, which are intended to gather specific information about the client’ s operations, risk profile and compliance controls. 34 Mainstream payment players interested in expanding their client base to matching services can implement SPDD-like questionnaires covering key areas listed in Graphic 1 below. 35
Graphic 1:
Suggested key due diligence areas for matching services
SERVICE DELIVERY( online or offline) |
CLIENT INTERVIEW ACTION MODEL
( virtual, in-person, non-face to face phone calls only, etc.)
|
CLIENT DUE DILIGENCE PROTOCOLS |
GEOGRAPHIC FOOTPRINT |
EXPOSURE TO HIGH- RISK OR SANCTIONS JURISDICTIONS |
DUE DILIGENCE AND IDENTITY VERIFICATION MEASURES, AND FREQUENCY CONDUCTED |
SCREENING PROCESSES AND TOOLS USED, IF ANY |
SOURCE OF FUNDS AND WEALTH VERIFICATION FOR HNW CLIENTS |
CHARGE-BACK RATES AND HISTORY OF FRAUD- RELATED LOSSES
PRIOR LEGAL ISSUES
GIFTING SERVICES AND ASSOCIATED CONTROLS
Source and visualization by: Trisha Gangadeen
ACAMS Today | September – November 2025 53