We enter 2025 facing waves of changes – regulatory, political and societal – the lightening pace of which is also reflected in the evolution of financial crime. To ensure true compliance with regulations and to meet their obligations around risk mitigation and customer security, institutions need to ensure they are positioned to adapt to emerging challenges in a dynamic and ongoing fashion.
Banks, broker-dealers, and digital asset platforms all bore the brunt of regulatory fines for AML non-compliance findings issued in 2024, with North America accounting for an overwhelming 95% of the $4.6 billion in global financial penalties levied during the period.1 Given this represents a triple digit percentage increase in fines, in 2025 firms can expect to see even greater scrutiny – and repercussions – for non-compliance amid heightened expectations and expansion of enforcement from regulators.
Those repercussions extend beyond financial penalties of course, encompassing damage to brand reputation, erosion of customer trust, and threats to operational resilience. Embracing advanced technologies, balancing data protection compliance with breaking down data silos for 360-degree view of all risk and cultivating a culture of proactive compliance are essential to meeting regulatory requirements for managing risks effectively.
In the realm of compliance and risk-based technology, a plethora of recognized vendor solutions – including Verafin, SymphonyAI, NapierAI, NICEActimize, Moody’s, FIS, Quantexa, ComplyAdvantage, Palantier, SAS and Oracle – which present opportunities for financial institutions to unify, future-proof and enhance their AML programs.
A Strategic Approach
Maximizing the value of technological investments requires a strategic approach, including operational target state definitions, control frameworks and technology footprint redesign, with an emphasis on operational resilience and optimization. Technological compatibility, organization’s information security (InfoSec) policies, transparency and accountability when it comes to AI are often barriers to implementing new or upgraded compliance software solutions suitable for real-time responses in AML and Fraud.
Eliminating waste, diversifying technology and operational risk, focusing on value-add partnerships in both consulting and technology spaces offer the optimal path forward.
This comprehensive approach will ensure an organization's anti-money laundering (AML) program will withstand not just regulatory scrutiny but move in tandem with evolution of financial crime used cases (e.g. human trafficking, crypto, organized crime typologies, insider threats, etc.) and compliance landscape.
Organizations need to unify data silos securing access to real-time data for enhanced AML, support insider threat (Know Your Employee) and fraud monitoring. In addition, they should consider prioritizing expansions in Model Risk Management and integration of AI solutions to support consistency in investigations and regulatory filings. Detection models need to account for the rise of virtual currencies and darknet market typologies, support used cases that cover customers and supply chain partners, assess direct or correspondent relationships with entities, and factor in third-country risks into the overall ratings.
Experience has shown, however, that while many such activities are initiated across financial institutions – and their scope and budgets subsequently expanded – few achieve tangible results within the short timeframes set by regulators. This can be attributed variously to a lack of focus and understanding within organizations of their gaps and alignment to regulatory expectations; a lack of expert talent or advisory to support transformations or lookbacks; and/or mixed results in the ability of third parties to deliver on their contractual obligations.
Conclusion
A unified approach to AML compliance should be a priority in 2025, and it will need to be supported by expert advice and dynamic technology that can bring in changes in real-time. Having complete oversight over all areas of financial crime and compliance can lead to significant productivity gains and cost benefits while reaching needed level of effectiveness. Organizations should accordingly pause and take stock of current efforts and investments to ensure they can double down on the right partnerships to successfully navigate the turbulent waters ahead.