In this episode of AML Voices, Elliot Berman leads a discussion on how AML programs can keep up with a fast-moving regulatory environment. Joined by Rachel Byrne, Senior Vice President and Head of AML Governance at PNC; Megan Nelson of Financial Crimes Risk Strategy and Governance at Truist; and Alan Ketley, member of the AML RightSource International Advisory Board and former Executive Secretary of the Wolfsberg Group, the panel starts with the pace of change. That includes a steady stream of proposed and enacted rules in the US, and the EU harmonization effort under AMLA.
The conversation then turns to taking the long view and to the balance between efficiency and effectiveness. Megan explains how to plan for people, process, and technology over several years and how to build systems that can adapt to future changes, such as beneficial ownership exemptive relief. Rachel explains how she tells leadership what a change actually means for the institution, beyond the headline, using the Corporate Transparency Act and the CDD rule as her example. She also describes technology as a way to move people to higher-value work rather than as a reason to cut staff. Alan argues that each part of the SAR chain optimizes for its own efficiency and that the system as a whole suffers for it. He calls for closer work with law enforcement and FIUs to improve the quality of reporting, not just the volume. The panel also discusses the proposed US AML program rule and its definition of an effective program.
The session closes with advice on working with examiners. The panelists recommend frequent, open updates, sharing bad news early, and having the courage of your convictions when you propose a change instead of asking permission. Each panelist then gives a final takeaway. Alan urges practitioners to comment on proposed rules and to read the Wolfsberg Group's papers on effectiveness. Rachel stresses a strong culture of compliance and a renewed commitment to the mission, even with less regulatory pressure. Megan encourages teams to check whether their governance framework fits the pace of change they face today.