Building and Executing a Modern AML Strategy: People, Process, and Community

Modernizing AML isn’t just about technology. It’s about building a culture, empowering people, and fostering collaboration both inside and outside your organization. That was the central theme of the latest session in Quantexa’s Modernizing AML webinar series, featuring industry leaders Sarah Beth Felix, Founder, Palmera Consulting and  Becky Schauer Robertson, EVP, BSA Officer - Director Financial Crimes Compliance, Blue Ridge Bank, N.A.  

Here’s what we learned about moving from strategy to execution in AML modernization. 

1. Culture of compliance comes from the top 

A strong compliance culture starts with leadership. Both Sarah Beth and Becky agreed that AML can’t be a checkbox exercise. It must be mission-critical, with the Board and senior management actively engaged. 

Becky reflected on the shift over the past two decades: “Years ago, we were an afterthought. Now, we’re at the forefront; sometimes because of regulatory trouble, but increasingly because Boards recognize the value of what we do.” She stressed the importance of keeping the Board informed and building trust: “If you don’t feel like you have that trust with your Board, it might not be a good fit.” 

Sarah Beth added practical indicators of a healthy compliance culture: “If you’re the only one talking in Board meetings, or you’re constantly begging for resources, that’s a red flag. Boards that ask questions and proactively support staffing and technology are the ones driving real change.” 

Key Takeaway: 

Boards need members with compliance backgrounds or at least a natural curiosity about risk and regulation. When Boards are engaged, AML becomes a growth enabler, not just a cost center. 

2. Specialization beats generalization in AML talent 

The panelists agreed on the fact that the AML field is plagued by an overabundance of generalists. Community banks often expect one person to be an expert in every compliance area, but true effectiveness comes from specialization. 

Sarah Beth put it bluntly: “You can’t be equally good at all areas of compliance. AML is nuanced. We need specialists who can think like criminals and who understand typologies and can operationalize them.” 

Becky echoed this, advocating for AML roles to report directly to the Chief Risk Officer or CEO, not just the Chief Compliance Officer. “That seat at the table establishes the culture of compliance,” she said. She also highlighted the importance of investing in talent: “I’d rather pay a good salary for one talented person than hire ten who can’t do the job.” 

Upskilling advice: 

• Encourage subject matter expertise, not just cross-training. 

• Use threat assessments (not just risk assessments) to identify resource gaps. 

• Focus on developing investigative skills—especially the ability to “think like a criminal.” 

3. Investigations require better data and realistic KPIs 

Investigations are at the heart of effective AML, but pain points are abound. For example, poor data at account opening, lack of frontline training, and unrealistic KPIs that don’t reflect investigative complexity. 

Becky stressed the need for better customer due diligence and internal collaboration: “Your lines of business are the first line of defense. Train them to spot unusual activity and ask questions.” 

Sarah Beth highlighted the importance of understanding typologies beyond structuring: “Most investigators don’t know what a shell company looks like. That’s a huge gap. And unrealistic KPIs, like rewarding the fastest alert closures, don’t fit the AML world.” 

Action points: 

• Invest in data quality and contextual information. 

• Train investigators to recognize complex typologies. 

• Align KPIs with investigative realities, not just volume metrics. 

• Train your LOBs to spot and escalate suspicious customers/activity. 

4. Threat assessments should replace generic risk assessments 

Both panelists advocated for a shift from broad, generic risk assessments to targeted threat assessments. Start with AML/CFT National Priorities, analyze your products and customer base, and use real data (like NAICS codes) to identify where your risks truly lie. 

Sarah Beth’s advice: “Now is the time to burn down your old risk assessment and start fresh. Regulators appreciate a thoughtful, threat-based approach.” 

Action points: 

• Start a new, fresh threat-focused risk assessment, not broad categories. 

• Align assessments with AML/CFT National Priorities. 

• Analyze products and customers using real data to pinpoint high-risk areas.  

5. Collaboration goes beyond formal partnerships 

Collaboration is more than just compliance. Becky and Sarah Beth championed both formal and informal partnerships within the industry and with law enforcement. 

Becky encouraged active participation in information-sharing initiatives like 314(b): “If you sign up, participate. Respond promptly. And don’t be afraid to reach out to peers for advice.” 

Sarah Beth advocated for informal public-private partnerships: “Build relationships with local agents. Share trends and typologies—no PII needed. These connections pay off far more than formal programs alone.” 

Something worth noting is that law enforcement agencies, including the IRS and HSI, collaborate closely with the private sector to combat financial crimes. For example, the IRS recently launched the CI First initiative to strengthen information-sharing with financial institutions. As part of this effort, the agency has shared investigative statistics demonstrating how BSA data is used in financial crime investigations and has hosted Executive Forums to engage industry leaders directly. 

6. Remembering the human mission in AML 

With regulatory pressure, technology change, and evolving criminal tactics, it’s easy to lose sight of the mission. Both panelists urged AML professionals to reconnect with their purpose. 

Sarah Beth: “The reason we do this is to stop human trafficking, fentanyl trafficking, and protect vulnerable people. If you feel disconnected, reach out to law enforcement, learn about local trends, and refocus on the impact you can have.” 

Becky: “Believe in yourself. Know that your work is meaningful even if you don’t always get feedback. You’re making a difference, piece by piece.” 

Final thoughts on modernizing AML 

Modernizing AML is about more than systems and software. It’s about leadership, specialization, collaboration, and a relentless focus on the mission. As the panelists reminded us, the work we do benefits our communities and that’s worth fighting for. 

To find out more about Sarah Beth, Becky and other AML experts and their journeys, dive into our Human Side of AML series and watch part one of the series.