As Head of AML Commercial Strategy at Nasdaq Verafin, and a practitioner with two decades of experience in financial crime prevention, I’ve witnessed the evolution of our industry from multiple vantage points. This year, I had the privilege of joining fellow experts and practitioners to explore the most pressing AML trends of 2025 and what we can expect as we move into 2026. Shaped by our discussion, here are my perspectives on the regulatory shifts, increasing complexity of financial crime, technology landscape and innovations that will shape our future.
AML Compliance Trends in 2025
2025 has been a year of notable regulatory change. We’ve seen a shift in tone from both government and regulators, with the introduction of the Streamline Act in the Senate and new SAR FAQs from FinCEN. The OCC’s decision to end money laundering risk system data collection for community banks, along with a pause on the Corporate Transparency Act (CTA) and the Foreign Corrupt Practices Act (FCPA), all signal a lighter regulatory touch — at least for now.
But what does this mean for AML programs? Many institutions are in a “wait-and-see” mode. While the level of regulatory scrutiny and some processes may be loosened, most are maintaining the status quo, wary of the long-term implications. The reality is that lighter exams and less experienced examiners may miss critical risks, and while the idea of reduced regulatory burden is appealing, it’s essential not to lose sight of our core mission: detecting and deterring financial crime in order to pass along intelligence to law enforcement. The industry’s cautious optimism is tempered by concern that reduced oversight could lead to resource cuts and diminished investment in technology — at a time when criminals are only ramping up their efforts.
Increasing Complexity of Financial Crime
If there’s one constant in AML, it’s that criminals are always a step ahead. In 2025, the complexity and scale of financial crime have reached new heights, fueled by advances in AI. We’re seeing a surge in deepfakes, synthetic identities and sophisticated fraud schemes. Criminal organizations now operate like diversified businesses, combining proceeds from drug trafficking, human trafficking and various scams to maximize their illicit gains.
The sheer volume of data — money movement, pre- and post-transaction events and network associations — makes it increasingly challenging to spot the critical threads that can unravel complex criminal networks. As practitioners, we must remain vigilant and leverage targeted solutions and activity analysis to stay ahead. The diversification and professionalization of criminal enterprises mean that one small piece of data can be the key to exposing a much larger scheme.
Evolution of Artificial Intelligence
Efficiency has been a driving force in 2025, with institutions turning to AI and automation to streamline non-value-added activities. Generative AI, once a buzzword, has matured into a practical tool. Banks are experimenting with use cases, moving beyond the “hammer and nail” approach to more nuanced, effective applications.
Agentic AI, the next evolution, is particularly promising. Unlike traditional generative AI, Agentic AI can reason, plan, execute multi-step tasks and make recommendations with minimal human oversight. At Nasdaq Verafin, we’ve seen Agentic AI accelerate investigations and automate end-to-end workflows. For example, our Sanctions Digital Worker can distinguish false positives from actual hits and provide decision recommendations, freeing analysts to focus on more complex cases. This technology is beneficial to institutions of all sizes, helping large teams redeploy resources to higher-value work and enabling smaller teams to expand their capabilities.
Risk management remains a top concern. Institutions are at varying stages of AI maturity, from those just starting to think about deployment and governance, to those actively using generative and agentic AI in daily operations. Regardless of where you are on the journey, it’s clear that AI is no longer optional — it’s essential for keeping pace with evolving threats.
2026 Predictions: Agentic AI
Looking ahead, agentic AI will continue to transform AML operations. The technology is ripe for automating routine tasks such as sanctions screening, enhanced due diligence (EDD) and suspicious activity report (SAR) investigations. By leveraging link analysis, consortium data and machine learning, we’ll be able to identify more sophisticated financial crime rings operating across multiple financial institutions and borders.
While some fear that AI will eliminate jobs, I believe it will shift the workforce toward more complex investigations. Routine, level-one tasks — often handled by offshore teams — will be automated, allowing institutions to redeploy talent to areas where human judgment and expertise are irreplaceable. The mix of people will change, but the need for skilled investigators will remain strong.
2026 Predictions: Consortium Data
Consortium data is poised to be a game-changer in AML. At Nasdaq Verafin, our consortium network spans 2,700 customers, enabling us to build profiles for more than 800 million entities and counterparties. This collective intelligence allows institutions to see beyond their own walls, identifying high-risk customers, shell companies and mule accounts across the network.
The power of consortium data lies in its ability to share relevant risk attributes without exposing personally identifiable information (PII). By tagging and analyzing customer behaviors, institutions can spot patterns and connections that would be invisible in isolation. As criminal organizations diversify and operate across multiple banks, consortium data becomes non-negotiable for effective financial crime prevention. If we don’t embrace this approach, we risk falling behind.
Key Takeaways for AML Teams
As we close out 2025 and enter 2026, several themes stand out:
- Efficiency and Effectiveness: Maximizing workflow efficiency is critical. AI and automation are powerful tools, but must be implemented thoughtfully.
- Evolving Threats: Criminals are exploiting emerging technologies. We must fight fire with fire, using advanced analytics and AI to stay ahead.
- Collaboration: Consortium data and peer networks are essential for rooting out complex financial crime. Don’t go it alone — lean on your peers and collective intelligence.
- Embrace Change: Invest in new technologies and don’t let skepticism or organizational inertia hold you back. The future of AML depends on our willingness to innovate.
My advice to fellow AML professionals: build strong peer networks, embrace AI and consortium data and remain vigilant. The challenges ahead may feel daunting, but with the right tools and collaboration, we can continue to protect our institutions and society from financial crime.
For more on 2025’s AML Trends & Technology, watch the full webinar.
About the Author:
CHUCK TAYLOR
CAMS, CAFP, Head of AML Commercial Strategy, Nasdaq Verafin
Chuck serves as the subject matter expert on AML regulations, industry trends, and best practices for financial crime prevention for Nasdaq Verafin. His role involves providing strategic insights to enhance the company’s financial crime solutions and assisting clients in navigating complex compliance requirements.
Prior to joining Nasdaq Verafin, Chuck served as Executive VP, Head of Financial Crimes Advisory (FCA) at AML RightSource. The FCA Practice at AML RightSource is a full-service advisory consultancy providing BSA Program support for all types of covered financial institutions.
Prior to Joining AML RightSource, Chuck was SVP and BSA Officer for City National Bank (CNB) a subsidiary of Royal Bank of Canada (RBC). Chuck had oversight responsibility for all aspects of the BSA function including maintenance of the Bank’s BSA program, BSA Risk Assessment, AML Transaction Monitoring, Currency and Suspicious Activity Reporting, Customer Identification Program, Sanctions filtering and BSA Training.
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