News

If years were movies, 2024 was an epic that ended somewhere in the middle. What do the next 12 months hold in store for the global financial-services industry?

Senior regulators, law enforcement officials, compliance officers, attorneys and other sources shared their predictions for the coming year with moneylaundering.com reporters Gabriel Vedrenne and Chelsea Carrick, and London bureau chief Koos Couvée.

An edited transcript of their conversations follows.

On regulatory priorities:

Grovetta Gardineer, senior deputy comptroller for bank supervision policy, U.S. Office of the Comptroller of the Currency: In 2025, the OCC will continue working with FinCEN and the other federal banking agencies to implement the AML Act. While responsibility for implementation falls primarily on the Treasury Department and FinCEN—with the OCC and other agencies having a largely consultative role—we will still work to ensure the changes made to the BSA regime can be effectively implemented by OCC-supervised institutions.

Other trends likely to shape compliance in 2025 include the potential for continued sanctions-related complexity based on geopolitical events; AML- and sanctions-related risks associated with continued adoption of innovative products and services, including through fintech partnerships; integration of multiple areas of risk into the risk-assessment process; and a continued increase in fraud-related crimes as well as a potential evolution of fraud schemes.

Braddock Stevenson, former deputy associate director of enforcement, FinCEN: I see regulators placing more pressure on banks to show they are actively monitoring their fintech relationships. Conducting an independent audit probably won’t suffice anymore—the new expectation will be active engagement. Regulators will make sure this is happening during the examination process, which is the easiest lever they have to pull. Another expectation we’ll see—and that we saw with TD Bank—is that foreign banks move decision-making and compliance staff to the U.S.

Mark Francis, director of enforcement, wholesale and unauthorized business investigations, U.K. Financial Conduct Authority: Financial crime will remain at the heart of the next FCA strategy. We will share the good and poor practices we observe across industry so firms know what good looks like and can learn from others, and we will continue to evolve our approach to enforcement, focusing on cases that are most likely to drive impactful deterrence. With three-quarters of fraud originating online, we will keep pushing for social media and big tech platforms to play their part too.

Didier Banquy, president of France’s AML Advisory Board, also known as COLB: The financial intelligence unit will soon host our next plenary with a specific focus on new digital technologies and crypto assets. But criminals do not give up proven, old-fashioned methods, so COLB will also hold a meeting on cash use in early 2025. Parliamentary work will meanwhile continue on a draft bill on drug-related money laundering.

France will submit its regular follow-up report to FATF in 2025 aimed at demonstrating AML authorities have made progress towards understanding new threats and an even more granular, risk-based approach towards supervision and enforcement. We will also lay the groundwork for a new national risk assessment for the next evaluation, and improve statistical collection so we can demonstrate effectiveness using relevant indicators.

Anton Bronnimann, head of the Money Laundering Reporting Office of Switzerland: Our priority is to keep enhancing our IT, to streamline STR processing, but also to reach interoperability with other public agencies so that we can receive information from justice and police databases automatically. At the moment, it’s done manually.

We see big risks among VASPs, from which we received around only 200 STRs in 2023. In Austria, Netherlands, Luxembourg and the U.K. these numbers are exploding, but we don’t see that in Switzerland. VASPs are the biggest risk I see at the moment, as they are self-regulated in Switzerland. The country is attached to the model of self-regulation, but we have to make sure it doesn’t translate into subpar supervision and enforcement.

On geopolitics:

Todd Clements, senior vice president, complex crime investigations, Citibank Europe in Poland: The situation in Syria, the weakening of Hezbollah—we know it’s going to have an impact, because Hezbollah is one of the principal money-laundering organizations in the region. Organized crime reacts to geopolitical events, and our team will watch and react to how criminals and terrorists adapt.

Zia Ullah, co-global head of corporate crime and investigations, Eversheds Sutherland: Sanctions will continue to be top of the agenda for financial institutions for a variety of different reasons. Under Trump there will be changes from a geopolitical perspective, but more specifically, changes to the Russia sanctions regime based on how the war in Ukraine plays out. If there is a negotiated settlement, you might see divergence between the EU and the U.K. on one side and the U.S. on the other in terms of sanctions.

More generally, the broader regulatory impact of geopolitical change undoubtedly means that financial institutions will have to stay sharp in terms of horizon scanning, mapping new risks and so on. Regulators now expect institutions to have hard and fast plans in place to respond quickly to whatever geopolitical changes may occur.

Christine Wimmer, team head of AML standards, KfW IPEX Bank in Germany: With so many conflicts in the world, such as in Ukraine, Syria and Gaza, and rising tensions between China and Taiwan, for example, if we were to fear something, it would be in the area of sanctions, though we would be much better prepared for new restrictions than we were prior to 2022.

On AML reform:

Stevenson, now of counsel, Paul Hastings: It will be interesting to see if the Corporate Transparency Act survives the nationwide injunction meted out in the Eastern District of Texas, given the changes in the political environment, and what will then become of FinCEN’s proposal to integrate the beneficial-ownership requirements into the CDD rule. I think we may also see more clarity around U.S. cryptocurrency regulations as they relate to [decentralized-finance] protocols on hosted wallets and stablecoins.

Editor’s note: A three-judge panel in New Orleans stayed the nationwide injunction of the CTA on Monday, Dec. 23, pending the final outcome of the Treasury Department’s appeal. A second panel reinstated the injunction Friday.

Carolin Gardner, head of AML, European Banking Authority: I would anticipate that AMLA [the Anti-Money Laundering Authority] from about mid-next year will become an active player in setting standards and expectations, which will be quite a significant change for national AML supervisors and their autonomy. AMLA also has to recruit more than 400 staff, so it’s not inconceivable that national authorities lose employees to the new agency.

The EBA has certain powers in relation to AML, but they pale in comparison to what AMLA will have, so it’s essentially rejigging the entire supervisory framework into something much more ambitious and harmonized. We’ll probably see changes in the approach of national authorities in anticipation of the new supervisory framework by the end of the year, including in relation to their entity-level risk assessments and supervisory methodologies.

Jean-Christophe Cabotte, deputy director, French Prudential Supervision and Resolution Authority, or ACPR: With AMLA, financial institutions have to get themselves in gear so they can provide the necessary submissions in the required format on time. This will be the back-office aspect of AMLA next year, but it’s crucial because the inability of some to meet their obligations would distort the ranking and selection of entities placed under AMLA’s direct supervision.

Jaap van der Molen, head of financial crime detection, ABN AMRO in the Netherlands: 2025 is important for further fleshing out the EU’s new AML Regulation, as we and our entire customer base—we have 5 million customers—must meet the new requirements by July 10, 2027.

We see different levels of risk-based supervision and varying degrees of focus on technical compliance with laws and regulations across the EU. In sum, the uncertainty around the precise requirements of the AML Regulation and 6AMLD—and the convergence of risk-based supervision across the EU and under AMLA—will make for an interesting period.

Wimmer, of KfW in Germany: We’ll also monitor what types of personnel AMLA will hire to get an idea of whether we are heading towards a more practical or more formal style of supervision. In Singapore, for example, the supervisor adopted a very practical, effectiveness-led approach, but Europe might go the other way, with lots of data collection.

Banquy, of France’s COLB: Next year will be largely devoted to the transposition of the EU AML package at the national level, with many countries facing challenges. Although most provisions are due to come into force in 2027, some will apply one year earlier and require us to transpose them as soon as 2025.

On the ‘known unknowns’ of 2025:

Stevenson: The Trump administration’s policies towards regulatory oversight and enforcement are uncertain. Previously, the Trump administration had issued a lot of memoranda that restricted regulators from using guidance as a tool for enforcement. I expect those to come back.

Michael Beckwith, former chief of transnational organized crime, Eastern District of California: Predicting the incoming administration’s actions is obviously difficult, but AML will probably be more-often framed in the national-security context. Specifically, there will be more focus on Chinese money-laundering organizations and sanctions evasion, fentanyl and the broader drug trade. FinCEN could appeal the nationwide injunction of the CTA or possibly even take a different approach, but I don’t think the law is going away.

Prosecutions will shift towards drug trafficking, and that shift will include more prosecutions in the AML space to address cartel money laundering and Chinese money-laundering organizations. I also expect more individual prosecutions, more individual accountability, but only in those very specific spaces of national security and drug trafficking.

On the challenges that financial institutions face:

Van der Molen, of ABN AMRO in the Netherlands: For banks, attracting and retaining talent will remain a top challenge. We need good analysts; people with knowledge and professional competence at the intersection of finance, economics and crime, but we also need good trainers, and people who can develop sound policies and internal standards and write guidance and reports.

On all fronts—not just on the compliance side—the labor market remains tight. We’re often fishing in a very small pond.

John Tobon, assistant director of countering transnational organized crime, Homeland Security Investigations: A major threat we will continue to see in 2025—and that we still do not know enough about—is black-market currency exchanges, of which there are hundreds for every legitimate foreign-currency exchange. The largest one we’re dealing with now is Chinese underground banking. Illicit funds are bought and sold on these markets. We know they exist, but we don’t know how far their tentacles reach. And these proceeds are financing international trade. When goods move across borders, the funds that are being used to pay for those goods are coming from unregulated black markets. And this is a direct challenge to financial institutions, because criminal organizations are in direct competition with financial institutions in terms of trade finance.

Clements, of Citibank Europe in Poland: The challenge is that people can be organized criminals one day; terrorists or political figures the next day; or they’ll be making money out of sanctions evasion. Last year, we did a lot of work on illicit gold in Africa, evasion of the Russian oil price cap, destabilization of the Sahel region under Russian influence, and the United Arab Emirates, which is still a hub of illicit finance. These will all remain areas of focus.