From Volume to Judgment as FinCEN Forces AML Into Its Next Phase
For decades, anti-money laundering compliance has been defined by accumulation. More alerts, more filings, more controls, more documentation. Each layer added with the quiet understanding that no one would be faulted for doing too much, only for doing too little. The result was not failure, exactly, but a kind of defensive equilibrium. Programs became expansive, but not necessarily incisive. Activity was measurable. Effectiveness was not.
