Navigating the AML Crossroads: 2025 in Review and What's Next

In this candid year-end conversation, John Byrne and Sarah Beth Felix dissect an unprecedented year in AML enforcement. Felix, President of Palmero Consulting and creator of "Dirty Money Weekly," describes what she sees as systematic dismantling of AML infrastructure despite stated priorities of combating fentanyl and transnational criminal organizations. With only four enforcement actions from traditional federal banking agencies compared to FINRA's 20+ penalties, the landscape has shifted dramatically. The discussion explores Treasury's proposal to give FinCEN veto authority over banking agency BSA decisions - a move Felix warns could create massive bottlenecks. They examine troubling patterns in recent OFAC sanctions penalties where entities disregard guidance while violations flow through traditional banks. Felix shares skepticism about AI replacing the "hyper suspicious" human judgment essential to AML work, noting AI tools consistently fail basic sanctions questions. The conversation addresses the stark gap between U.S. and European cryptocurrency regulation, with America applying 40-year-old money service business laws to digital assets while the EU has comprehensive frameworks like MiCA. Looking ahead to 2026, Felix urges AML officers to use reduced regulatory scrutiny strategically - eliminating legacy policies that waste time while remembering everything missed now can trigger future enforcement. She emphasizes focusing on cartels and foreign terrorist organizations, which now carry criminal liability for banking officers, and proactively auditing customer sanctions programs.