It’s early in the year, but already it feels like everything is moving at once in the world of financial crime.
AI is moving from experimentation into expectation. Regulatory change across Europe is on the horizon. Cost pressure remains intense, and senior leaders have very little time to step back and think strategically.
Before things get too far down the line, this is a good opportunity to take stock of how you are going to make a real impact this year and end it in a stronger position than you are now. What is actually going to make the difference?
I speak every day with Financial Crime leaders across the first and second line. From those conversations, a small number of priority areas stand out that I would focus on right now. I have outlined these below as suggestions to help you get off to a strong start.
Most Financial Crime environments have evolved in silos. AML, KYC, sanctions, fraud, policy, operations, data, technology and change are often managed as separate domains. There is rarely a shared understanding of how they connect end to end.
This lack of shared view has practical consequences. Duplicated effort is commonplace. Controls are designed without a clear line of sight to upstream obligations or downstream operational impact. Priorities compete rather than reinforce one another.
It is also common for senior leaders to bring reference models from previous institutions. Those perspectives are usually well-founded, but when everyone is working from a slightly different model, agreeing on the right priorities takes more effort than it should.
Creating a simple, visual blueprint of the current Financial Crime environment helps make conversations more straightforward by showing how obligations, risks, controls, governance, processes, data and technology relate to one another, without needing a fixed or idealised model.
Used well, this supports more consistent discussion across the first line, second line and operations. It also helps create a clearer, more coherent message for the MLRO, COO and board.
The benefits of this approach are better decision-making, fewer disconnected initiatives, and a stronger ability to explain how the overall system operates when regulators ask questions.
Many Financial Crime programmes carry unnecessary cost because obligations have never been clearly worked through in the context of the institution’s actual business.
Supervisory expectations are often interpreted generically. Controls are added or tightened without sufficient consideration of where requirements genuinely apply, how they should be interpreted for specific products or customers, and how they translate into day-to-day delivery.
The outcome is that workload increases, cost rises, and controls do not perform as intended.
A sustained focus on obligation clarity can change this situation. That means being explicit about which requirements apply in which contexts, translating supervisory expectations into guidance that makes sense to customers and delivery teams, and being clear about what is required from a regulatory perspective versus what flows from the institution’s own risk appetite.
When that distinction is clear, risk assessments become more robust and control design becomes easier to explain and defend. Reviews and inspections become more predictable, and issues are simpler to resolve.
Cost pressure is now a constant feature of Financial Crime leadership. Yet cost is often discussed without a clear link back to regulatory obligation.
Leaders acting on behalf of the business or first line are not always able to articulate what regulation requires versus how the organisation has chosen to implement those requirements. As a result, leadership teams often lack a clear view of where the institution is exceeding minimum expectations.
Without that visibility, proportionality is difficult to apply in practice.
Bringing this into the open supports better decision-making. Ensuring the business understands the regulatory baseline well enough to engage meaningfully with the second line, and quantifying the cost of discretionary choices where possible, creates the basis for a more informed discussion with executives.
This allows decisions to be taken deliberately and explained with confidence.
Pressure to adopt new platforms and AI-enabled solutions is increasing rapidly. In many organisations, technology discussions are moving ahead before there is a clear understanding of the underlying problem.
In practice, these discussions often sit on top of issues around data quality, operating models or control design. If those foundations are weak, new tools won’t fix them, and you won’t get the performance improvement you are looking for.
Tying technology decisions to a clear articulation of what the organisation is trying to achieve helps avoid this. Being explicit about current constraints and the maturity of the environment before assessing solutions reduces the risk of costly mistakes.
Vendor selection also benefits from being treated as a strategic decision, rather than a response to a single operational pain point.
Many leaders are fed up with diagnostics that restate known issues without translating into practical improvements. Insight on its own does nothing to change outcomes.
Instead, use reviews to clarify priorities and sequence action, rather than to catalogue every issue. That will help maintain momentum. Each piece of work needs to lead to specific, realistic next steps that teams can deliver within existing constraints.
Keeping scope tight enough to allow progress, while recognising that any change must work within the wider Financial Crime system, makes improvement more likely to stick.
Working through these areas at a brisk pace early in the year should help you strengthen foundations, make trade-offs visible, and direct more effort towards work that genuinely reduces risk and operational strain.
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