Introduction: Industry reports show that private wealth growth is accelerating and diversifying at an unprecedented rate, offering enormous opportunity for financial institutions – along with rising risks. To capture this growth, firms must engage new clients with increasingly sophisticated, tech-enabled solutions, and invest in strengthening their compliance and risk controls in an ever-more complex world.
As the world exited the throes of the COVID-19 pandemic, financial markets saw an unexpected outcome: an explosion of private wealth during the recovery period, which we analyzed in our 2022 blog post. A Credit Suisse report from that time noted that in 2021, there was a large increase of “ultra-high net worth” (UHNW) individuals around the globe, accounting for those with more than $30 million in assets. The report also found that UHNW individuals were increasingly consolidated in the US and China, accounting for more than three-quarters of all such individuals around the globe.
Fast forward three years – what are wealth professionals seeing now? What can they expect to see? Some broad trends appear to be emerging, as shifts in wealth generation and technology continue to impact wealth managers by presenting new compliance challenges.
A Surprising Financial Hotspot
According to UBS’ 2025 Global Wealth Report, the North America stampeded ahead in 2024 with almost 12% wealth growth, but another surprising region saw an equally big jump. Eastern Europe matched North America’s world-leading total personal wealth growth at 12% – an especially impressive number considering regional instability amidst the ongoing Russia-Ukraine conflict. The region saw notable wealth growth in Poland, Latvia, Lithuania – and just to the southeast, wealth also jumped in Bulgaria, Greece, and Turkey. With this surge in wealth, new risks arise due to documented money laundering issues in the region. According to a 2023 report in The Banker, illicit financial flows in Eastern and Southeastern Europe have been estimated to surpass $1 trillion each year, enabled by weak rule of law, corruption, and political interference. To take advantage of growing wealth in regions like Eastern Europe, the most well-positioned wealth managers will need robust access to compliance experts with niche language and cultural expertise – or the risks could be catastrophic.
Source: UBS GWM Report 2025
The Rise of the EMILLI
UBS’ report highlights a growing trend in wealth holdings around the world. In 2022, UHNW individuals were all the rage, but recent years have seen an explosion in the number of “EMILLIs,” or “everyday millionaires” with $1 million to $5 million in assets. This class has more than quadrupled since 2000, now numbering in excess of 52 million and holding nearly $107 trillion in assets. These EMILLIs aren’t flashy tech gurus and Wall Street brokers – they’re your coworker whose home exploded in value during the pandemic, or maybe your next-door neighbor who started a successful new e-commerce business. Compliance professionals who are used to vetting clients with well-established public profiles will have to adjust to properly vet and ascertain the source of wealth of these newer clients, who may have scant or even non-existent public profiles.
“…recent years have seen an explosion in the number of ‘EMILLIs,’
or ‘everyday millionaires’ with $1 million to $5 million in assets.”
A Looming Landslide of Wealth
An $83 trillion global wealth transfer is anticipated over the next 25 years, driven by key markets around the world. Most of this wealth transfer will happen between generations, as $74 trillion is expected to be passed on by an aging Baby Boomer generation to their descendants. While this effect will be most keenly felt in the US, emerging markets with relatively old populations, such as Brazil and mainland China, will see a similar cascade of wealth across generations. As this global transfer unfolds, wealth professionals will be tasked with onboarding new clients whose wealth is mostly or fully derived from their inheritance, rather than more traditional sources of wealth such as a job or an investment portfolio. In this new client scenario, it would be best practice to conduct an appropriate review of the “wealth generator” to properly assess for the source of wealth.
Crypto, From Pariah to Powerhouse
In 2022, the price of Bitcoin was languishing at a more than 50% decline from its peak in 2021, fueled in part by the Biden Administration’s highly skeptical regulatory approach to cryptocurrency trading. Many market observers wondered whether crypto would stick around in casual investors’ portfolios, especially following the collapse of major crypto exchange FTX in November 2022. Fast-forward to 2025, and the price of Bitcoin continues to hover at or around all-time highs more than $100,000, fueled in large part by the second Trump Administration’s permissive approach to crypto. No matter what your opinion is of cryptocurrency and its technological merits, the technology appears set to continue to grow as an option for investors – along with its inherent risks. With this increase in popularity, crypto money laundering has continued to make headlines. As more HNW individuals grow rich from cryptocurrency, wealth managers will need to adopt new compliance techniques and technologies to vet crypto wallets, and to ensure that they are not exposing themselves to potentially dirty funds and reputational harm.
Future-Proofing Private Wealth: Compliance Challenges
As these new trends continue to accelerate and cause difficulty for KYC teams, recent tech advancements are simultaneously easing the burden of some compliance work. The past few years have seen an explosion in artificial intelligence capabilities, as AI-powered platforms continue to proliferate and offer new, more efficient services to companies. These AI services have begun to expand into the compliance space, with tantalizing possibilities for beleaguered KYC teams. AI-enabled tools can rifle through databases at an unprecedented speed while extracting and summarizing key details and can even conduct automated monitoring of countless data streams to ensure that your team is always up to date on the latest news. The time-consuming information gathering and sorting can now be accomplished in seconds, giving compliance professionals more time to analyze results and to zoom out and focus on the big picture. Combining cutting-edge technology and subject matter expertise will help keep compliance programs ahead of would-be financial criminals.
Looking ahead, 2026 promises to be a pivotal year for global wealth creation, presenting lucrative growth opportunities for financial institutions and wealth managers. As the world’s assets swell and the millionaire population expands rapidly, wealth management firms must adapt their business strategies, implement robust frameworks, and partner with experienced subject-matter experts to ensure they onboard only the most reputable clients.
Frequently Asked Questions:
What are the biggest compliance challenges for private wealth in 2026?
New regulations, including the implementation of new Anti-Money Laundering (AML) rules for investment advisors, an increasingly complex global landscape and ongoing digital technology shifts are amongst some of the notable compliance challenges on the horizon.
How is AI used in KYC for high-net-worth individuals?
Using AI for this purpose involves several key applications, including enhanced risk assessment and due diligence. AI increases the ability to analyze large datasets from multiple sources of public records much faster. Additionally, AI can perform adverse media checks quickly and accurately by scanning for potential reputational risks using Natural Language Processing (NLP).
What are EMILLIs and why are they a compliance risk?
A recent term for “Everyday Millionaire,” a segment of the population defined as individuals with $1 million to $5 million in assets that is rapidly growing. EMILLIs present a new compliance risk primarily due to gaps in AML and KYC procedures. Financial firms must update their compliance programs to address this growing segment, which can fall outside the typical parameters of either high-net-worth or traditional retail clients.
How can investment banks (and wealth managers) verify source of wealth?
One key method is independent verification. Performing enhanced due diligence (EDD) of the primary wealth generator is best practice. EDD typically includes research of public records, commercial databases and a deep internet review. These methods yield information leading to a comprehensive understanding of the activities and sources that have contributed to a client’s total wealth over a period of time.