Asset tracing has undergone a marked transformation as digital footprints become increasingly central to financial investigations. Monika Rihma, Managing Director at Mintz Group, offers perspective on this shift, drawing on her experience in former Soviet states, where wealth is often obscured behind complex ownership structures.
This article explores two interconnected but distinct areas of financial investigation. First, we examine how asset tracing practices have evolved in the digital age, exploring the challenges of tracking both traditional and digital assets across jurisdictions. In the second part, we turn to due diligence processes and how they complement asset recovery efforts while serving different business objectives.
While digital tools and data aggregation have enhanced investigative speed and reach, they have also introduced fresh challenges. Social media provides a wealth of personal information, yet growing digital awareness has prompted individuals to curate or obscure their online presence. Meanwhile, virtual banking and cryptocurrencies add further complexity to asset concealment.
Rihma underscores the continued importance of human intelligence and source verification; the interplay between digital tools and traditional investigative methods is increasingly relevant amid rising regulatory scrutiny, shifting due diligence expectations, and evolving international legal standards.
This balance is particularly crucial as recent policy changes such as shifts in FCPA enforcement reshape compliance requirements for cross-border transactions.
The Evolution of Asset Tracing in the Digital Age
Digital technology has reshaped asset tracing practices since 2015. “The proliferation of social media has changed our approach,” Monika Rihma explains. “People share aspects of their personal lives online, often revealing information about their wealth, location, and assets without intending to do so.”
Data aggregators now compile information from corporate registries across multiple jurisdictions, reducing initial research time from weeks to minutes. Yet Rihma notes clear limitations: “Data from aggregators serves as a starting point, helping identify which jurisdictions merit further investigation, but it cannot be relied upon in isolation.”
The digitisation of public records varies by region. Major financial centres maintain comprehensive digital archives, while other markets retain paper-based systems or partial digital records. This creates distinct operational requirements, where some jurisdictions offer direct access to verified information, while others necessitate on-ground investigation to gather corporate data.
Subject behaviour has adapted to this digital environment. “High-net-worth individuals now demonstrate greater awareness of their digital presence,” Rihma notes. “Many have withdrawn from social media or implemented structured approaches to information sharing.”
Investigation methodologies have evolved accordingly. Data points from property listings, planning applications, and maritime records provide contextual evidence when examined together.
While data aggregation platforms expedite the mapping of ownership patterns, interpreting these structures requires methodical analysis. The combination of digital tools and investigative expertise has become standard practice, with technology enabling data processing while investigators interpret patterns and assess business contexts not apparent in digital records alone.
Navigating International Legal Frameworks: Monika Rihma on Cross-Border Challenges
International asset tracing presents distinct regulatory challenges, Monika Rihma explains. “Privacy laws create clear divisions between jurisdictions. While the UK maintains public access to corporate records, EU member states often restrict similar data under protection regulations.”
The 1958 New York Convention establishes the basis for international asset enforcement, with courts recognising arbitration awards across signatory states. This treaty shapes investigation methods, particularly as digital transformation alters how evidence is gathered and verified. A White House Executive Order from February 2025 suspending FCPA enforcement has implications for international due diligence standards.
“This regulatory shift requires careful evaluation,” Rihma notes. “While some firms might reduce their processes, many maintain comprehensive investigations to protect corporate interests and manage risk.”
Jurisdictional cooperation determines investigation outcomes. Rihma points to specific contrasts: UK companies maintain digitised, searchable records, while several EU jurisdictions restrict access to comparable data.
“When digital records prove incomplete, or exist only in paper format, we implement market-specific protocols,” she explains. This approach reflects her experience in markets where traditional investigation methods remain essential.
The integration of digital capabilities and legal requirements has reshaped investigation parameters. This adaptation becomes particularly relevant as new financial technologies emerge, with digital assets adding another layer to cross-border investigations.
Challenges of Digital Assets in Modern Asset Tracing
The emergence of cryptocurrency and virtual banking has introduced new complexities to asset tracing. “When cryptocurrency first appeared, the industry faced a knowledge gap,” Rihma explains. “Today, while tracing digital assets requires technical expertise, we have established clear investigation protocols.”
Cryptocurrency exchanges cooperate with fraud investigations more readily than in previous years. This shift aligns with market development, though Rihma notes specific limitations: “Virtual banks operate under different standards across jurisdictions. Fund transfers through these platforms require adapted monitoring approaches.”
The technical requirements of cryptocurrency investigations have led to specialist roles. “Teams include cryptocurrency experts who understand blockchain analysis and digital wallet tracking,” Rihma says. This expertise has become standard as virtual assets feature in asset structures.
Digital asset tracing indicates changes in financial behaviour. “Many individuals now hold both traditional and digital assets,” Rihma observes. “Understanding these patterns helps identify potential asset movements.” Investigators now apply blockchain analysis alongside established investigation methods to track these transfers.
Emerging Trends in Asset Tracing
As digital tools and market expertise converge, new investigation patterns have emerged. “Data aggregation platforms process information at scale,” Rihma explains. “This increased data volume requires systematic verification protocols.”
AI technology offers additional analytical capabilities. “Machine learning can identify patterns across datasets,” Rihma says, “but the value lies in combining these insights with investigative experience.”
Technology has influenced how subjects control their digital presence. “Many individuals restrict their online footprint,” Rihma notes. “This has led to refined information gathering methods.” Her investigations balance digital analysis with direct verification to ensure accuracy.
Market requirements for due diligence have also adapted and Rihma’s work has had to adapt to reflect current client priorities: “Organisations want clear insights about potential partners and investments. Digital tools support this analysis, but direct investigation remains essential for actionable intelligence.”
Source verification has taken on renewed significance. “In today’s information environment, fact verification requires multiple reference points,” Monika Rihma says. “This approach extends to environmental and governance considerations, which now form key components of risk assessment.”
Impact of Digital Operations on Due Diligence Practices
Remote operations have changed how firms conduct due diligence. “Digital access to corporate records has reduced location constraints,” Rihma explains. “Most preliminary investigations now proceed from any point where data access exists.”
Market-specific requirements persist. While financial centres maintain digital records, other jurisdictions rely on paper-based systems. “These markets require local presence for document verification and records access,” Rihma notes.
Data accessibility follows regional patterns. “The UK provides searchable records that support thorough due diligence,” Rihma says. “By contrast, EU jurisdictions often limit data access under privacy regulations.” These differences determine how teams approach investigations in each market.
Remote work has redefined cross-border investigations. Rihma advocates a measured approach to digital capabilities: “Technology enables efficient data gathering, yet accurate interpretation depends on understanding local business practices and regulations.”
This balance between digital tools and market expertise points to emerging trends in investigation methodology.
ESG Considerations in Modern Due Diligence
The expansion of due diligence to include environmental, social and governance factors reflect this market evolution. “ESG compliance now forms a standard component of partnership evaluation,” Rihma explains. “This encompasses both regulatory requirements and reputational elements.”
ESG verification requires specific methods. “Public records provide foundation data,” Rihma explains. “Understanding operational practices demands direct investigation.” As market perception of due diligence has shifted companies now view these processes as risk management tools, Rihma observes. “This reflects a clearer understanding of reputational exposure.”
ESG analysis has refined traditional due diligence methods. “We evaluate environmental practices, social responsibility measures, and governance structures as core business metrics,” Monika Rihma says. “This approach leads to questions about how asset tracing and due diligence complement each other in modern practice.”
Distinguishing Asset Tracing from Due Diligence
Asset tracing and due diligence fulfil different roles in risk management. “Due diligence examines potential partners before transactions,” Rihma explains. “Asset tracing identifies assets for recovery after disputes or suspected fraud.”
Timing defines these processes. “Due diligence provides pre-transaction analysis,” Rihma says. “Asset tracing responds to claims after business relationships break down.”
Each practice follows its own methodology. “Due diligence assesses risk through established protocols,” Rihma notes. “Asset tracing locates concealed assets through targeted investigation.” This difference guides team composition and approach.
The New York Convention shapes asset tracing work. “Enforcement capability influences where we conduct investigations,” Monika Rihma says. “We prioritise jurisdictions that recognise international arbitration awards.”
These practices require particular expertise. “Due diligence examines business operations and compliance,” Rihma observes. “Asset tracing focuses on finding assets and preparing for recovery.” This specialisation has led to new challenges in both fields, particularly as concealment methods evolve.
The practice of asset tracing adapts to market evolution. “Effective investigations blend established methods with new capabilities,” Rihma observes. “Evidence standards remain constant while techniques advance.”
Digital innovation and regulatory changes have reshaped global business practices. The combination of technology, market knowledge, and investigative expertise defines current asset tracing work.
“Understanding this environment shapes investigation strategy,” Monika Rihma says. “Success in modern asset tracing depends on applying both digital tools and established verification methods.”