Strengthening the Gatekeepers – A New Era in AML strategy

July 24, 2025 The global financial system operates around the clock—cryptocurrency markets never close, global remittances exceed $794 billion annually, and institutions like JPMorgan Chase process over $52 million in payments each day. Within this dynamic and high-stakes environment, Anti-Money Laundering (AML) analysts play a pivotal role in reviewing millions of transactions and customer activities to detect and prevent illicit financial activity.

These professionals serve as critical gatekeepers, protecting the financial system from exploitation by illicit networks—including transnational criminal organizations (TCOs), terrorist groups, and both state and non-state actors—who exploit geopolitical complexities to evade detection. According to the 2025 Worldwide Threat Assessment by the Defense Intelligence Agency and the Annual Threat Assessment of the U.S. Intelligence Community, these threats are both persistent and evolving.

Illicit actors and networks are particularly adept at leveraging emerging technologies—including artificial intelligence and blockchain obfuscation tools—to automate laundering processes and mask transactional origins. They often target financial institutions with weak compliance frameworks or exploit fintech platforms and decentralized finance (DeFi) ecosystems that lack robust oversight. In some instances, state actors provide safe havens or logistical support, further complicating enforcement efforts.

The consequences of these illicit financial flows are profound. Beyond enabling criminal enterprises and terrorism, they destabilize economies, fuel corruption, and erode the integrity of financial institutions. As these networks grow more advanced, the burden on AML analysts and financial institutions to detect and disrupt them increases significantly.  This necessitates a change in strategy of how best to equip the gatekeepers with the skills and abilities to combat a rapidly advancing threat.

A critical function the AML analysts fulfill is the direct contribution to law enforcement efforts through the production of Suspicious Activity Reports (SARs), tools instrumental in identification, disruption, and apprehension of threat actors. Despite the critical nature of this role, there is currently no standardized framework defining the core competencies or training expectations for AML analysts at various levels—entry, intermediate, supervisory, and advanced. Neither the Financial Action Task Force (FATF) nor U.S. regulatory bodies provide a baseline for training standards or competency development.

Given the hybrid nature of AML work—spanning compliance, national security, commercial enterprises, and criminal intelligence—there is a pressing need for a national standards initiative that includes:

A structured roadmap for AML analyst career development to ensure skills and talent evolve alongside the threat landscape that includes clearly defined core competencies across career stages; and

Baseline training standards and measurable learning outcomes that include strategic use of emerging technologies, such as AI, as well as effective communication skills in enabling more effective financial crime risk management.

Modeled after the Department of Justice’s Minimum Criminal Intelligence Training Standards and the Central Intelligence Agency’s Career Analyst Program, this approach enables closer alignment of private sector AML analysts with their intelligence analyst and investigator counterparts in government. With a goal to enhance the effectiveness of AML programs and better equip analysts to counter and convey critical information about increasingly complex illicit finance schemes, integration can be done through a phased approach that also addresses the growing use of AI in financial systems, which, while powerful, may inadvertently diminish critical thinking skills if not balanced with robust human expertise.

Establishing a set of core competencies – critical thinking, analytical reasoning, and technical and geographic proficiency – ensures gatekeepers are better equipped to detect illicit financial activity and, similar to peers in government, focused on a set of national training priorities. In this context, critical thinking involves applying logic and questioning assumptions to solve problems, evaluate information, and identify biases. Analysts must be able to frame complex issues, pose challenging questions, and construct logical arguments supported by relevant data.

As AI capabilities continue to evolve, analysts may rely less on manual open-source research and more on AI-generated insights. However, it remains essential that they apply established analytic methods to evaluate information—whether generated by AI or sourced independently — assess its completeness, and identify relationships between analytical elements, including organizational context.

In addition to critical thinking and analytical skills, AML analysts must maintain high levels of technical and geopolitical proficiency. This entails proficiency in emerging technologies—including AI and blockchain coupled with an understanding of geopolitical landscapes and their implications for regulatory and operational risk.  Perhaps, most importantly, they must be equipped to navigate complexity, ambiguity, and incomplete information—skills that no amount of technical knowledge alone can replace.

AML analysts are the frontline defenders of the financial system. Establishing standardized core competencies and baseline training standards is essential to recognizing their critical role and enhancing global efforts to combat transnational criminal organizations and illicit finance.