AML Conversations A Conversation with Sarah Beth Felix
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Jun 9, 2025 
Join Sarah Beth Felix, President of Palmeiro Consulting and co-founder of Acceleron Bank, as she dives into the evolving challenges of Anti-Money Laundering. She sheds light on the BSA oversight hurdles anticipated for 2025 and the regulatory complexities surrounding cryptocurrency. Sarah discusses the implications of FINRA's enforcement actions and emphasizes the need for transparency and effective risk management in banking. With insights on anti-corruption measures, she points to a future where compliance is more critical than ever.
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Reduced AML Exam Intensity 2025
- In 2025, many community banks experienced shorter AML exams and reduced regulatory scrutiny.
- Board members are reallocating AML staff due to the perceived paused enforcement, risking future compliance issues.
Threat Mindset Over Checkboxes
- Many AML deficiencies stem from a lack of a criminal 'threat mindset' rather than mere checkbox compliance.
- Proper threat assessment drives better training, monitoring, and resource allocation in AML programs.
CTA Rollback Impairs Law Enforcement
- The rollback on enforcement of the Corporate Transparency Act (CTA) weakens law enforcement’s ability to pierce corporate veils.
- Illicit actors bypass foreign registration by exploiting onshore/offshore state laws, diminishing AML effectiveness.