AML in 2025. The year of technology.

As we end 2024, we look at the Financial Action Task Force's (FATF) actions and global trends to provide a likely direction for AML in 2025. 

FATF focuses on next-level transparency, risk management and cooperation.

Country-specific mutual evaluation reports show that since 2022, FATF has been pushing a consistent global theme: enhancing AML regulatory frameworks. The UK's 2022 report noted a robust AML system with room for improvement in beneficial ownership transparency. Australia and New Zealand were identified as having less mature regulatory landscapes, requiring enhanced supervision and risk assessment capabilities. 

While last year’s Plenary explicitly called for global improvements:

• Enhanced beneficial ownership transparency
• More sophisticated risk-based approaches
• Improved international cooperation in financial investigations

The trajectory for 2025 points towards deeper compliance, focusing on improving transparency, system interoperability, and strategic risk management across borders and technologies. 

An unstable world.

When we look at what’s happening globally, we find that three mega-trends are reshaping the global financial integrity landscape:

• Ongoing international conflicts
• Artificial Intelligence's transformative potential
• Increasingly sophisticated financial crime techniques

Geopolitical tensions: The sanctions imperative requires an advanced, real-time response 

The ongoing conflicts in Ukraine, potential tensions in the Asia-Pacific region, Middle East uprisings and complex international relations have transformed sanctions from a compliance checkbox to a strategic imperative. Combine this with FATF’s transparency and proactive risk management emphasis, we predict that 2025 will see the broader introduction of sophisticated technology-powered AML programmes allowing for:

• Real-time global screening capabilities
• Enhanced due diligence for international transactions
• Advanced sanctions management
• Advanced technological integration
• Dynamic and real-time risk assessment methodologies
• Beneficial ownership transparency ​​to help identify when criminals are using intermediary countries and entities to bypass international restrictions.

Artificial Intelligence: It's end of days for analogue checks

Artificial Intelligence represents both an extraordinary opportunity and a significant risk for AML. The emergence of sophisticated deepfake technologies and synthetic identities has fundamentally altered the landscape of client verification. With that in mind we predict that 2025 will see the end of days for simple document checks. AI-powered verification will become the new standard, requiring technological investment that allows for:

• Multi-layered identity verifications
• Advanced biometric authentication for high risk clients or transactions
• Sophisticated document validation techniques
• Continuous monitoring and adaptive risk assessment

Sophisticated crime requires sophisticated AML

AI-powered ID synthesis. Geopolitical conflict exploitation. Sanctions complexities and grey zones exploitation. Hyper-complex international corporate ownership structures. Jurisdictional arbitrage that hides beneficial ownership…these are just a few of the sophisticated crime techniques that directly challenge and require corresponding technological and methodological advancements in AML. This is why we predict 2025 will see the start of the introduction of technological features that will ultimately deliver:

Hyper-integrated compliance ecosystems

• Internal AML systems
• External regulatory databases
• Global sanctions lists
• Internal client management systems
• Pre-verified entities

Intelligent process automation

• Rules-driven workflow optimisation
• Automatic triggering of enhanced due diligence processes
• Real-time risk escalation workflows
• Automated documentation requests, review and routing
• Intelligent case management 

Zero-touch compliance workflows

• Exception-based human intervention 
• End-to-end AML and client onboarding
• Continuous risk monitoring

Self-service change management

• Self-directed system improvements through rules and requirements
• System flexibility for near-instant legislative change accommodation
• Automatic policy and procedure adjustments
• Embedded and dynamic risk assessment 

Conclusion

2025 will bring a swath of technological advancements that help compliance leaders to fundamentally transform their AML approaches, reduce operational costs, and minimise regulatory risks. As financial crime becomes increasingly sophisticated, firms will embrace intelligent, integrated technologies that offer real-time risk assessment, advanced verification, and adaptive compliance mechanisms. 

The future of AML is not just about meeting regulatory requirements, but moving up a level, creating dynamic, technology-driven ecosystems that can anticipate, detect, and respond to emerging financial risks with speed and precision. 

For compliance leaders, the message is clear: technological investment is no longer optional, but an imperative for maintaining financial integrity in an increasingly complex global landscape.