Architecting the Future of AML: Aligning Mission, Leadership, Data, and Technology

Financial crime is a dynamic, borderless and by no means victimless threat—driven by bad actors who continually adapt their tactics, exploit technology to commit fraud, and often outpace even the best-prepared institutions. Countering these forces takes more than rules or software; it requires people dedicated to defending communities, protecting the vulnerable, and strengthening the integrity of the financial system. That describes strategist and entrepreneur Vic Maculaitis, who is not unlike a “systems architect” for modern anti-money laundering (AML) programs, thanks to his efforts to rethink how AML structures and processes work together to serve their mission.  

From dreaming of working in federal law enforcement at age 10 to leading risk transformations at major banks, his career has spanned public service, corporate leadership, and consulting. Today, as the founder of i3strategies®, a market research and strategy consulting firm specializing in financial crime risk and compliance, Maculaitis takes a broader view of the AML ecosystem, advocating for more innovative structures, stronger leadership, and data-driven innovation.  

Whether working to disrupt terror finance networks or helping midsize and community banks protect their customers, Maculaitis stays true to one principle: putting the mission first. That mindset, shaped by decades of experience across government and private industry, gives him a rare vantage point on what’s working—and what must change—for modern AML programs to truly succeed. 

Reclaiming the core mission and purpose of AML 

Maculaitis has seen firsthand how many AML programs have become more about satisfying regulatory expectations than actually disrupting criminal networks. He believes years of prioritizing checklists and paperwork have left many financial institutions, large and small, struggling to measure whether they are truly making progress in stopping crime and protecting customers and communities. The tension between purpose and process, he says, is limiting the overall effectiveness financial crime prevention. 

From his systems-level vantage point, Maculaitis sees the forces that fuel this disconnect. On one side are government agencies focused on their mission: investigating crime, dismantling illicit networks, and prosecuting bad actors. On the other side are financial institutions under pressure to generate profits and manage shareholder expectations while navigating complex regulations.  

Somewhere in the middle sit the regulators—playing a necessary, well-intentioned role, but one that, from Maculaitis’s perspective, can sometimes add more friction than clarity to AML efforts. He argues that regulators’ focus on prescriptive requirements and strict documentation can shift banks’ attention from meaningful fraud risk management and AML innovation—in other words, away from the mission. 

“The regulator, unfortunately, can often be a force that steers financial institutions’ focus in the direction of compliance rather than the disruption of illicit activity and combating financial crime,” he says. 

Applying innovation and advanced technology in combating financial crime 

Maculaitis says AML efforts need to align more closely with their core mission of fighting financial crime. Yet he also acknowledges that many banks hesitate to rethink their approach out of fear of compliance missteps. So, rather than viewing regulation as an obstacle, he suggests that banks aim to proactively partner with regulators and share their plans early to secure buy-in for innovation. “If you have transparency and a thoughtful plan, it’s hard for someone to look at that plan and say you shouldn’t do it,” Maculaitis explains.  

He also suggests that prudential regulators (who oversee bank safety and soundness), law enforcement, and agencies like FinCEN should better define their respective roles and coordinate oversight efforts, to reduce duplication and preserve accountability. A more integrated, outcomes-focused approach, Maculaitis argues, could shift the industry from simply passing exams to actively stopping financial crime.  

“We need better strategies and organization, and to apply technologies that allow us to actually tackle the problem,” Maculaitis says. He points to legacy transaction monitoring systems as a significant weakness in current AML programs. While these systems are essential for AML regulatory compliance, they can churn out thousands of false positives, forcing investigators to chase routine activity while sophisticated criminals slip through undetected. “We have a massive army of people looking at non-risk, while the bad actors are running amok,” he says. 

Advanced tools like contextual monitoring solutions, machine learning, and agent-based AI systems hold enormous promise—but only if they’re built on the right data foundation. “If you have high-quality data that is consolidated, then you can apply advanced technologies to it, so there is speed to understanding and decision-making,” he explains. 

While machine learning has already proven its value in fraud detection, he believes Maculaitis remains underused for broader financial crime risk. “Machine learning should almost be a staple technology that’s leveraged in your overall monitoring strategy,” he says. He also sees opportunity for analysts to use agent-based AI systems to triage data and detect anomalies more quickly and accurately. “If the bad actors are using AI, we should be using it too.” 

Still, Maculaitis cautions that even the best AML tools and software cannot do it all. True AML transformation, he insists, requires a clear mission and the courage to challenge outdated practices. 

Looking ahead: building a future of renewed AML effectiveness 

Based on his decades of experience in the field, Maculaitis’s advice to AML professionals is clear: Don’t lose sight of the mission. Whether they work in government or the private sector, he says practitioners should stay focused on protecting communities and the financial system, while adapting to the realities of business and shareholder expectations. 

“You have to understand all the relevant business mechanics in addition to running the AML program,” he explains. “You also need to keep your team productive and motivated to protect customers.” 

Maculaitis would like to see financial institutions empowering their executives to oversee all financial crime risk areas and supporting them with consolidated data and integrated technology. That structure, he believes, can transform AML from a box-checking exercise into a mission-driven defense where data isn’t siloed and decision-making is conducted with speed and confidence. 

He also remains optimistic that AML programs can evolve over the next five to 10 years to become more strategic, more technology-enabled, and better aligned with their core mission. “The status quo in AML must change,” says Maculaitis. “The question we must ask is, ‘Is what we are doing reducing financial crime?’ That has to be the measure of success we focus on moving forward.”