If you’d asked me what I took away from this year’s AML Partnership Forum in Washington, D.C., I’d probably ask how much time you’ve got. But if I had to sum it up: The law is still the law. Non-enforcement is not the same as non-compliance.
Is that a bold statement? Maybe.
Is it on the minds of everyone in this space – public and private sector alike? Absolutely.
Over the course of three packed days, financial crime compliance professionals, law enforcement leaders, and even a few marketers dug into topics ranging from regulatory uncertainty and crypto crime to the late-night stressors that keep both sides of the partnership awake. The real value of this event lies in its authenticity. No stagecraft, no sales pitches – just real-world examples, practical takeaways, and mutual respect between those identifying suspicious activity and those chasing it down.
And while I’ll respect the Chatham House Rule, one thing is clear: everyone left with food for thought (and yes, the ice cream bars were also excellent), new connections, and a sharper sense of the extensive challenges ahead.
The Forum’s structure – deliberately designed to foster dialogue between law enforcement, other government officials, and financial institutions – delivers something rare in this community: real-time insight grounded in operational reality, shared candidly. These aren’t hypothetical conversations; they’re the ones shaping how programs evolve, how enforcement is prioritized, and how risk is mitigated.
It’s also becoming evident that the political winds are shifting how law enforcement agencies engage. In many circles, there are more questions about what’s coming than clarity about what’s passed. And to those public servants who continue to show up each day to fight financial crime – despite uncertainty around their own futures – a sincere appreciation for all you do for what has become a connected “industry” over decades. Keep bringing the fight to the criminal organizations feeding off of the vulnerabilities of an expansive global financial system!
On the private sector side, the signals are clearer. We’re seeing slippage in momentum – particularly around BOI compliance (see recent Corporate Transparency Act updates) – and increasingly cautious language from FinCEN around enforcement.
But ambiguity doesn’t mean the risk has magically dissipated. While there will undoubtedly be more to come on these fronts, it still seemed to be a secondary discussion item amongst the crowd.
In fact, what struck me most wasn’t what was said, but what was shared – the common, unspoken thread across nearly every conversation: volume.
Record-breaking transaction volumes. An explosion in fraud cases. Escalating sanctions enforcement. A confusing pause in attacking clear corruption and bribery. Growing domestic and foreign terrorist threats. And bolder, larger, and more complex crypto heists than previously uncovered. And almost as if in a fever dream, these risk areas continue to strengthen while compliance teams are expected to do more faster, with less margin for error and budgetary resourcing. No doubt 2025 is gearing up to be an interesting and chaotic year for financial crime compliance professionals, at a minimum.
This brings me back to that opening line: non-enforcement is not the same as non-compliance. The regulatory lens of 2025 may appear softer right now, but the resolve among the professionals in this space remains rock solid. There’s a quiet pride in doing the right thing – even when there may not be one watching quite as closely. The true leaders in financial crime compliance aren’t cutting corners; they’re rowing upstream.
Some institutions may see today’s regulatory ambiguity as an opportunity to retreat. But many are doing the opposite—investing, partnering, and future-proofing. They're not retreating from their obligations; they’re recommitting to them.
What cannot be understated above is that law enforcement and members of the public sector’s financial crime compliance circles continue to push toward resolution and justice for any and all subverting or abusing the financial system.
As we look ahead, the path forward isn’t without complexity – but it’s also full of opportunity. Familiar guideposts are shifting and new threats are emerging. The work of financial crime prevention has never been more critical, and the resolve across this community is unmistakable. Whether in government buildings, FI compliance hubs, or vendor offices around the globe, there’s a shared recognition that the mission doesn’t pause just because the rules are evolving. If anything, it demands more clarity, more courage, and more collective action (Looking at you, 314(a)/(b)..).
The AML Partnership Forum reminded us that while the landscape may shift, the commitment to protecting the integrity of the financial system and society holds firm. From what I’ve seen, this community is not only prepared but also locked in its commitment to face whatever comes next. No matter what comes next, it is essential that we continue to commend and support the public part of this enduring partnership—their service is needed now, more than ever.