AML RightSource
Session Overview
AML RightSource's expert panel reviewed the most significant developments in financial crime compliance during 2025, examining both domestic and global challenges while looking ahead to 2026. The conversation covered regulatory changes, emerging risks, and practical strategies for compliance professionals navigating an evolving landscape.
Major Highlights
1. FinCEN FAQs: A Game-Changing Clarification
The panel identified FinCEN's Frequently Asked Questions—jointly issued with all federal banking supervisory agencies—as 2025's most significant surprise. These FAQs clarified three critical areas that had evolved into burdensome expectations without being actual requirements:
- SAR Decision Documentation: Financial institutions are not required to extensively document decisions not to file Suspicious Activity Reports, though the panel emphasized maintaining reasonable documentation remains prudent.
- Continuing Activity Reviews: No regulatory requirement exists to continuously monitor and re-file SARs on the same activity, particularly for automated transaction monitoring alerts
- CTR Structuring: Clarified that structuring analysis should follow the actual regulatory definition—transactions within a 24-hour period—rather than the expanded timeframes many institutions had adopted
The panelists agreed these clarifications present opportunities to reallocate resources more effectively while maintaining robust compliance programs.
2. The De-Banking Debate
The panel discussed the politicization of customer risk management decisions, with new scrutiny on what has been termed "de-banking." Several states have passed fair access laws, and the OCC issued a preliminary report identifying instances where institutions allegedly exited relationships for political or religious reasons. Key takeaways included removing "reputational risk" language from AML policies and ensuring exit decisions are based on quantifiable suspicious activity rather than qualitative judgments.
3. Artificial Intelligence: From Skepticism to Opportunity
All panelists acknowledged AI's rapid evolution in 2025 as a legitimate tool for financial crime compliance. Practical applications being explored include narrative generation for SARs, quality control automation, transaction monitoring alert analysis, and reducing administrative burden on investigators. However, institutions must address data security concerns, particularly around maintaining SAR confidentiality when using AI tools.
4. Fraud and Scams: An Escalating Challenge
The panel highlighted the continuing surge in fraud, particularly social engineering scams, business email compromise, and elder abuse. Fraudsters are increasingly sophisticated, often convincing customers to bypass security controls themselves. The panelists emphasized that while banks have improved detection capabilities, prevention remains challenging when customers unwittingly participate in schemes.
5. Regulatory Evolution and Uncertainty
Despite expectations, comprehensive AML reform regulations did not materialize in 2025. Meanwhile, the panel noted upcoming changes to Customer Identification Program requirements that allow institutions to obtain taxpayer identification numbers from sources other than directly from customers—a potentially significant operational improvement. Looking toward 2026, the panel anticipated continued regulatory evolution with some uncertainty about how far deregulation trends will proceed.