A conference room, second floor, glass walls. Three vendors have pitched this quarter. The fourth is mid-slide, talking through screening logic, case management workflow, deployment options, integration timelines, and support model. Around the table: the Head of Financial Crime Operations, the MLRO, and the Product lead.
The Head of Financial Crime Operations nods along. She has strong instincts about alert volumes, screening thresholds, false positives, and how the tool would affect investigator workload. What she does not have is a full view of cyber posture, deployment constraints, data architecture, or whether the platform will fit next year’s infrastructure plans.
The MLRO has a view on how this tooling will enable the organisation to fulfil its regulatory obligations, but whether it fits with the firm’s current and future products and services is a question mark to him.
The Product lead’s priority is getting the next product developed and launched to market. What happens in the nuts and bolts of monitoring customers, their behaviours and their transactions is of little interest to him.
After the meeting, the Product lead is pushing to pinpoint a solution so it can go through the approval chain. The MLRO pulls the Head of Financial Crime Operations aside. He asks her directly: who in this building understands financial crime policy, operational impact, technical integration, security, data governance, and vendor risk well enough to own this decision? Neither of them can name one person.
What they can both agree on is that while they are trying to ask the right questions of the vendor, they are also trying to identify where the current gaps are in the existing tech stack.
What We Are Seeing
Vendor selection was identified as a major challenge among the payment firms that attended our recent roundtable. Underneath that challenge lie two very distinct sticking points that the above scenario speaks to.
1. There can be significant confusion around ownership of vendor selection within the Financial Crime teams in payments firms, especially when it comes to whether this should lie with the first or second line of defence. Often vendors are selected without the right questions having been asked and/or not having the right people around the table.
2. As payment firms scale, their tech needs change. Systems that were suitable six months ago may no longer be fit for purpose.
The two problems meet at exactly the moment a firm needs to choose the latest technology, because by then, nobody quite owns that decision, and the stack itself was never designed with scale in mind.
The Solution
Getting technology selection right starts before any vendor is in the room. Three things need to happen first.
1 - Define ownership explicitly.
Vendor selection needs a named owner and a cross-functional panel that includes financial crime policy expertise, technical, architectural input, and commercial oversight, agreed before the first pitch, not assembled around the table on the day with limited prior warning.
2 - Assess the current stack honestly before evaluating what replaces it.
Firms scale, and a system that fitted previously may not fit now. That assessment should look at actual usage against original requirements, not just whether the system still runs. The gap between the two is usually where the case for change, or the case for staying, lives.
3 - Build the requirement, then test vendors against it, not the reverse.
A structured requirements definition, covering security, integration, data architecture, operational impact, and long-term scalability, gives a panel something concrete to hold every vendor to, including the validation evidence a good pitch on its own will rarely surface unprompted.
This is the approach BeyondFS took with a global financial institution still running a manual, email-based client servicing model that needed to move to a modern self-service portal. The system had to meet complex security, integration, and operational requirements across multiple business units while supporting the firm’s long-term digital strategy. BeyondFS defined the requirements, assessed 15 vendors against them, and led the full selection process through to final recommendation.
Within three months, the client had a clear technology roadmap and a detailed implementation blueprint, a scalable foundation that improved client experience, reduced operational effort, shortened processing times, and supported growth through greater automation.
BeyondFS has helped many clients select and implement technology successfully across financial crime and wider operational change programmes. Our proven approach reduces the risk of costly mistakes and gives clients confidence that the technology they choose will deliver lasting value.