Why 2025 feels different
Budget pressure, fast-shifting sanctions, and the first wave of AI-enabled financial crime
mean AML programs must be faster and more evidence-led. Below are the five trends that will
shape programs most in the next 12 months—and what to do now.
1) Smarter, smaller data beats “more data”
Regulators are pushing quality over quantity in monitoring. Watch for model governance
expectations around data lineage and feature explainability. Action: establish a
data catalog and retire fields you never use; measure precision/recall on each scenario.
2) Real-time sanctions risks spill into trade
Evasion now commonly uses layered corporate structures, trans-shipment, and service brokers.
Action: add trade & logistics indicators to sanctions screening (HS codes, vessel
history, intermediary ports), and document escalation playbooks.
3) Perpetual KYC & continuous KYB
Event-driven refresh is replacing rigid cycles. Action: wire new risk signals
(ownership change, adverse media spikes, geo-events) to trigger targeted refresh activity.
4) Model risk management becomes table stakes
Supervisors expect model inventories, drift monitoring, and challenger models—especially for
AI/ML. Action: appoint a model owner for each scenario; capture performance monthly;
validate annually, or sooner after population changes.
5) Talent shift to product thinkers
Leading teams mix investigators, product managers, and data analysts. Action:
establish a backlog, quarterly OKRs, and ship improvements in two‑week increments.
What “good” looks like by Q4
- Every scenario has a clear hypothesis and success metric.
- Alert volume and SAR conversion are tracked publicly on a team dashboard.
- Sanctions, AML, and fraud share an investigative glossary and playbook.
- Board reporting connects risk stories to quantified outcomes.
Bottom line: focus on explainability, event-driven reviews, and measurable outcomes.
That’s how AML functions keep pace in 2025.