
Navigating the AML Crossroads: 2025 in Review and What's Next
Dec 22, 2025
Join Sarah Beth Felix, President of Palmero Consulting and creator of the Dirty Money Weekly newsletter, as she critiques an unprecedented year in AML enforcement. She highlights a disturbing decline in infrastructure and enforcement actions, contrasting federal bank penalties with FINRA's surge. Felix warns about the potential bottlenecks from FinCEN's proposed veto authority and discusses the urgent need for banks to enhance sanctions due diligence. With skepticism about AI's ability to replace human judgment and a call for updated crypto regulations, she empowers AML officers to refocus priorities as we approach 2026.
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Regulatory Direction Contradicts Stated Priorities
- Federal banking agencies are moving opposite to long‑awaited harmonization and strengthening efforts.
- Many guidance pieces cut industry protections under the banner of efficiency, creating cognitive dissonance with stated priorities.
Enforcement Split: Banks Vs. FINRA
- Traditional federal banking agencies issued very few enforcement actions in 2025 while FINRA issued many AML penalties.
- This divergence suggests inconsistent accountability across regulators and shifting enforcement dynamics.
Avoid Creating A FinCEN Bottleneck
- Do not support a FinCEN veto over banking agency BSA decisions without assessing capacity impacts.
- A FinCEN final‑review role would likely create bottlenecks and delay enforcement that drives institutional change.
