Publication
Licensed detection agents: The case for financial crime bounty hunters
Miles Kellerman, Assistant Professor at Leiden University, argues that governments should consider empowering financial crime bounty hunters by creating Licensed Detection Agents to address structural failures in current systems for detecting financial crime.
- Author
- Miles Kellerman
- Date
- 05 November 2025
- Links
- Read the full article here
Kellerman examines why global efforts to detect money laundering and market manipulation often fall short. He argues that the prevailing gatekeeper model, which relies on private companies to report suspicious activity, faces a structural conflict of interest that limits its effectiveness. Kellerman introduces what he terms the Detection Trilemma, a set of competing demands involving data access, positive incentives and privacy protection. Current regulatory approaches, he notes, struggle to balance these requirements.
His proposed solution is a programme of Licensed Detection Agents, independent actors authorised to monitor financial transactions and rewarded for reporting credible intelligence to regulators. According to Kellerman, such a system would create a competitive market for detection and generate new information on criminal schemes while paying for itself through resulting fines and recovered assets. By applying the model to cases of market manipulation and money laundering in both the United States and the United Kingdom, the article shows how self interest can be channelled toward socially beneficial outcomes.