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3 Lessons for AML Modernization Success: Patience, Simplicity, and Building for the Future

At Ocean Bank, Alejandro Sardinas has helped shape a thoughtful approach to compliance transformation, guided by three principles: be patient, keep it simple, and design for the future.

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The Fincrime Pulse Report: U.S. Mid-size and Community Banks

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3 Lessons for AML Modernization Success: Patience, Simplicity, and Building for the Future

At Ocean Bank, Alejandro Sardinas has helped shape a thoughtful approach to compliance transformation, guided by three principles: be patient, keep it simple, and design for the future.

3 Lessons for AML Modernization Success: Patience, Simplicity, and Building for the Future

Long before he led efforts to modernize anti-money laundering (AML) programs, Alejandro “Alex” Sardinas was hooked on the idea of helping to solve crimes. At 13, while on a family RV trip from Miami to New York, he spent hours glued to a portable TV, binge-watching “Law & Order: Special Victims Unit.” And when he wasn’t caught up in the drama of Olivia Benson and Elliot Stabler, he was pulling out the board game Clue, eager to play detective himself. 

“For me, it was always about finding the answers to mysteries,” Sardinas says. His early passion for investigative work later inspired him to study criminal justice and psychology at college, with the intent of eventually joining a three-letter agency like the FBI.  

However, his quest for an investigator job took an unexpected turn when a BSA trainee posting at Ocean Bank popped up in his employment search results. Ocean Bank is a leading independent, privately held Florida bank serving local businesses and international clients. “I had no idea why a banking job was showing up in my search,” Sardinas recalls. “But my interest was piqued, so I said, ‘What the heck?’” 

Sardinas landed the role—and over the past 12 years, he’s built a career in financial crime compliance at Ocean Bank, rapidly progressing from trainee to analyst to supervisor. In his current role as Vice President and Regulatory Risk Optimization Manager, Sardinas explores emerging technologies like AI that can help Ocean Bank fight financial crime more effectively. 

Inspiring banks to hire differently and help build a talent pipeline 

When Sardinas joined Miami-based Ocean Bank, he was something of an anomaly. “I was probably one of, if not the only individual the bank hired with a criminal justice background,” he says. He notes that, at the time, most financial institutions sought to recruit professionals with finance or business administration degrees for analyst roles and did not typically seek out law enforcement hopefuls. 

That experience helped Sardinas understand quickly how narrow the AML talent pipeline can be. Through his work with the South Florida chapter of the Association of Certified Anti-Money Laundering Specialists (ACAMS), Sardinas has made a point of engaging with local universities to raise awareness of compliance careers—though he admits there is still a long way to go in building a robust talent pipeline. 

“Most students don’t know this profession even exists,” he explains. “We work in the dark more often than not. But if there was more awareness and understanding of what we do, I think we’d see a lot more interest because plenty of people—just like me—would thrive on the investigative aspect of the work.” 

Uncovering the deeper motives behind financial crime 

Sardinas credits his dual background in criminal justice and psychology with shaping his approach to AML compliance. “There’s always a motive in financial crime that goes beyond the money factor,” he says. “That’s why it’s important to look at crime holistically.” 

Instead of simply flagging odd behavior as suspicious, he believes analysts and investigators need to dig deeper and seek to answer a critical question: Why are people transacting this way? 

That mindset also helps Sardinas see beyond false positives. “A lot of investigators chalk something up as unusual and file a SAR. I like to take it further and think about the reasons for the behavior,” he says. 

Sardinas also considers how environment and context can influence criminal patterns. For instance, warmer climates may see more crime simply because more activity happens outdoors, while smaller cities might experience different types of fraud due to fewer diversions or entertainment options. 

By taking the environment into account, some activity that appears unusual at first may not be suspicious at all. “Context really matters,” says Sardinas. 

Taking a philosophical approach to modernizing AML programs 

Like many midsize banks, Ocean Bank faces resource constraints. “The industry is always challenged to do more with less,” Sardinas says. While large institutions can hire dedicated data scientists and rapidly test new technology, smaller banks don’t always have that luxury. 

That’s one reason Sardinas takes a thoughtful, human-first approach to modernization efforts at the bank. Over the years, he has helped to lead significant upgrades in areas like the Know Your Customer (KYC) process. His experience has also helped him to develop a clear philosophy for building more intelligent systems. Sardinas advises banks planning to modernize their AML program to: 

  • Be patient: While he understands the urge to move fast, Sardinas says rushing to implement emerging technology like AI can be risky—especially when the stakes involve regulatory scrutiny and customer risk. Instead, take the time needed for development and implementation to realize expected value. 

  • Keep it simple: Over-automating workflows can create complexity that is difficult to maintain, Sardinas says. He also warns that over-engineered systems can actually slow investigations when critical information isn’t surfaced at the right time. 

  • Design for the future: Intelligent systems should evolve as needs change. For example, Sardinas’ team integrated external data sources into Ocean Bank’s KYC platform to reduce manual upkeep. “We built features in a way that allows users to modify them going forward, instead of needing hard-coded changes every time,” Sardinas says. 

Visualizing a future of AML compliance that includes people + AI 

Sardinas sees AI, machine learning, and contextual analytics reshaping AML compliance in the years ahead. He predicts traditional rules engines will gradually be displaced, although not fully eliminated. “Generative AI is going to transition investigators from authors to editors,” he says. By that, Sardinas means investigators won’t always have to start a case file from scratch. Instead, AI will assemble much of the background and analysis, leaving people to review, refine, and validate the results. 

Contextual analytics will also boost efficiency by providing a holistic view of customer behavior rather than isolated transactions. Sardinas points to innovators like Quantexa, which uses AI to power contextual monitoring and give investigators a more complete picture of behavior. With broader adoption of AI, Sardinas believes tools like these will only help to accelerate investigations.  

However, while Sardinas is optimistic about AI’s potential to transform AML compliance and investigative work, he cautions banks not to view it as a silver-bullet solution or treat it merely as a cost-cutting tool. “The downside of the AI rave is that management often sees it as a way to reduce staff,” he says. Instead, Sardinas encourages banks to visualize a future of compliance that involves using AI to help AML professionals think more critically, work more efficiently, and adapt to evolving risks faster. 

Sardinas’ three recommendations—be patient, keep it simple, and design for the future—offer a blueprint for AML modernization, and a reminder of why the human element remains vital in this field. Technology can assemble case files, surface anomalies, and even spot hidden connections, but it’s people who bring context and motive into focus.  

“We’re here to identify bad actors, report them, and ultimately, protect communities,” says Sardinas. “That’s why I love what I do.” 

Read our FinCrime Pulse Report to learn more about the challenges facing U.S. mid-size and community banks.

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