AML compliance is how your business puts up barriers to financial crime. Every process or policy needs to work in the real world — not just on paper.

Start with your risk assessment. If it’s not driving decision-making, something’s off. This document isn’t meant to sit on a shared drive collecting dust. It should inform onboarding thresholds, Enhanced Due Diligence (EDD) triggers, and escalation protocols.

Keep it current. The risks you’re exposed to change as your business changes – new products, new customers, new jurisdictions. Your controls need to follow suit. Know Your Customer (KYC) and Know Your Business (KYB) checks allow you to build a clear enough picture to spot when something doesn’t fit. That means going beyond minimum requirements. If you’re seeing repeated mismatches, thin explanations, or inconsistent ownership structures, don’t just log it – interrogate it. 

Monitoring is your early warning system. But it’s only as good as the scenarios you build and the data that feeds them. False positives are inevitable, but if they’re drowning your team, that’s not a software issue – that’s a design flaw. Tune your rules, and don’t be afraid to rethink thresholds based on what your alerts are actually telling you.

Training can’t be theoretical. Your frontline teams need to know what red flags look like in the context of their work, not in generic policy terms. Give them real examples. Show them how to raise concerns. And back them when they do. Culture plays a bigger role here than policy ever can.

Financial crime risk is embedded in product design, tech infrastructure, customer experience, and commercial decisions. You need relationships across the business that let you challenge those areas – and be heard. Compliance has to be in the room early, not brought in after the fact. AML work is detailed, procedural, and relentless. But when it works, the impact is real – not just for your business, but for people and communities far beyond it.