Key Takeaways
- Compliance has entered its execution era. The focus is shifting from designing controls to executing outcomes consistently and transparently
- Regulatory expectations are converging. With the Anti-Money Laundering Authority (AMLA) now active in the EU, the EU Artificial Intelligence (AI) Act shaping explainability, and the GENIUS Act in the U.S. advancing interoperability, institutions must prove both intent and operational assurance
- Fraud typologies are evolving faster than static controls can adapt, which demands real-time monitoring and risk-based resource allocation
- Sponsor banks are now accountable for their FinTech ecosystems, requiring continuous oversight of partner compliance and transaction behavior
- Human-led crimes such as sextortion and trafficking are intensifying, while AI-driven partnerships are transforming compliance by orchestrating data, redesigning processes, and reskilling talent
- Data quality and orchestration are now as critical as policy itself. Clean data, explainable models, and trustworthy automation define modern compliance maturity.
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The shift in focus
The conversations at both the Association of Certified Anti-Money Laundering Specialists (ACAMS) in Las Vegas and Sibos in Frankfurt revealed a clear narrative: compliance and banking transformation are converging. These forums, one centered on Financial Crime and Compliance (FCC), the other on modernizing global finance — highlighted that the next competitive edge will come not just from innovation, but from the discipline of execution.
At Sibos, regulations took center stage. The EU’s AMLA, operational from July 2025, signaled a new era of coordinated supervision. Attendees explored how to translate AMLA’s mandates into practice, cross-border orchestration, harmonized rulebooks, and measurable assurance rather than checkbox compliance.
At ACAMS, conversations with financial institutions and service providers revealed shared challenges; however, diverse approaches indicate that multiple models can be effective in Financial Crime Compliance (FCC).
Fraud typologies are evolving faster than traditional controls can adapt. Sponsor banks are held directly responsible for their partner ecosystems, which extend oversight beyond onboarding to include real-time monitoring of FinTechs’ compliance and controls. Human trafficking has become one of the most pervasive global crimes, second only to drug trafficking, while counterfeit goods and digital scams are rapidly proliferating.
AI and transformation of risk management
AI was a unifying theme across both conferences. Institutions showcased how explainability and governance are prerequisites for innovation. Providers showcased orchestration frameworks that integrate rules, graph analytics, and machine learning to balance precision with transparency. Automation builds trust when it can explain its reasoning, comply with policy, and withstand regulatory scrutiny.
We observe that tier-1 firms are embedding model traceability, auditability, and policy alignment as core compliance requirements.
Regulatory recalibration in real time
As regulatory landscapes evolve, policy recalibration is already underway. Regulators are moving from procedural reviews to evaluating true program effectiveness. Financial Crimes Enforcement Network’s (FinCEN’s) adjustments to Ultimate Beneficial Owner (UBO) rules and its expanded focus on emerging threats: drug cartels, Chinese laundering networks, virtual currency kiosks, and sextortion, demonstrate how compliance priorities are shifting toward real-world risk. Even smaller institutions, such as credit unions, are reminded that the size of an institution does not exempt it from regulatory scrutiny. All stakeholders must modernize by investing in comprehensive risk coverage and ensuring continuous assurance.
Ultimately, risk and compliance are evolving from reactive control to proactive prediction. The real opportunity lies in anticipating future developments and developing systems that can recognize new patterns before they escalate into crises
From technology to execution
For years, financial-crime programs have revolved around technology gaps, better models, faster analytics, and smarter tools. But what both ACAMS and Sibos highlighted is that the true frontier isn’t technical capability; it’s execution discipline. The industry continues to struggle with what we call PTSD: process, technology, skill, and data debt.
• Process debt: legacy workflows optimized for periodic reviews rather than real-time operations.
• Technology debt: complex, layered systems that slows rather than strengthen compliance.
• Skill debt: shortages in model efficiency and governance, AI oversight, and data controls.
• Data debt: fragmented sources and poor lineage undermining decision integrity.
These debts quietly limit progress. Even the most advanced AI cannot produce consistent assurance on unstable foundations. The real task ahead is connecting people, process, and data into a coherent system of execution that turns insight into reliable action.
Closing thoughts
The conversations at ACAMS and Sibos made one truth undeniable: compliance has entered its execution era. The industry’s next challenge is overcoming its collective PTSD debt, outdated processes, fragmented technology, skill shortages, and data silos, to achieve truly trustworthy automation.
Momentum is building globally. The EU’s AMLA is raising the bar for supervisory consistency, the EU AI Act mandates transparency and human alignment in automation, and the U.S. GENIUS Act promotes interoperability and shared compliance intelligence. Together, they reflect a new age of regulatory collaboration, prioritizing transparency, accountability, and execution quality.
Sibos 2025 wasn’t about shiny tools; it was about building systems that can be trusted, automation that explains itself, data that connects seamlessly, and regulators who partner rather than police. ACAMS amplified the same theme, grounding it in human stakes: from evolving fraud typologies to trafficking and sextortion, compliance is no longer abstract. It’s about protecting people as much as protecting institutions.
We believe, the future belongs to those who can bridge vision and verification, those who can execute trust, at scale, every single day.
If you enjoyed reading this blog, check out our Financial Crime And Compliance (FCC) Operations Services PEAK Matrix® Assessment – Everest Group, which delves deeper into FCC.
To benchmark your FCC execution maturity, or explore its implications for modernizing Financial Crime and Compliance (FCC), please reach out to [email protected] and [email protected]
