Nov 17, 2025 Dr. Stephan Lemkens
ShareSpeed Is Becoming the New Regulatory Currency
The days when supervisors merely required banks to have an AML system in place are long gone. Today, regulators assume that institutions are capable of detecting suspicious activity. What matters now is how quickly and consistently the downstream processes operate. This is where the real risks have shifted, deep in the operational engine room of compliance, and this is exactly where regulators are focusing their attention.
What used to be sufficient, such as solid transaction monitoring or a well-defined investigation process, is no longer enough. Recent supervisory practice shows that while institutions often have strong detection mechanisms, they tend to falter at the critical moment when an alert must actually be investigated and reported.
The problems no longer arise at the point of detection but in everything that follows. A recent record fine of around €45 million in Germany highlights this shift. Regulatory failures today occur less at the beginning of the AML process and more at the end. This is where internal workflows are too slow, data isn’t consolidated properly, or reporting deadlines are missed due to manual tasks. This is not an isolated case but rather a structural trend across the market.
Inside the Compliance Engine Room: Where Things Are Breaking Down Today
The fact that speed has become the new currency in anti-money laundering has several causes. Transaction volumes continue to rise across nearly all institutions, and as a result, the number of alerts requiring daily analysis is also increasing. At the same time, authorities have long understood that money laundering does not wait until next week. Suspicious activity reports (SARs) that arrive too late lose their operational value because investigations are only effective when launched promptly.
Legal expectations are clear: reports must be submitted without delay. In today’s regulatory environment, this typically means hours, not days. Yet this acceleration meets processes that are still marked by media disruptions, redundant manual work, and limited transparency.
Europe Ramps Up: AMLA Sets a New Benchmark
In parallel, the entire European AML framework is shifting. With the new Anti-Money Laundering Authority (AMLA), the industry will face a supervisory standard that is far more demanding than what many countries are used to. The benchmark will be set by markets that have demonstrated not only thorough but exceptionally fast AML operations.
The Netherlands, for example, manage internal investigations and reporting within time frames that are nearly unthinkable in other European jurisdictions. Once AMLA is fully operational, expectations will shift significantly. The focus will no longer be on minimum standards but on best-practice performance. Institutions still relying on fragmented process landscapes will come under even greater pressure.
Why End-to-End Processes Are Becoming Essential
FürFor banks, this regulatory shift means one thing: institutions that continue to rely on isolated systems and manual workflows will face considerable risk. Data is often scattered across different systems. Analysts must manually search for relevant information. Escalations run through email, deadlines are tracked in Excel sheets, and expectations for speed and precision are rising at the same time.
This makes integrated end-to-end processes increasingly essential, from the first alert all the way to the final suspicious activity report. Modern systems support this by automatically pulling all relevant data into a case, structuring the investigation workflow, and reliably monitoring deadlines.
A key component is the reporting itself. A technical module that guides analysts step by step through the reporting process, automatically incorporates existing case details, and generates the official submission file, whether in goAML or FinCEN format, significantly reduces effort. It provides transparency and ensures that the entire process is documented in a way that can withstand regulatory scrutiny. It does not replace professional judgment, but it does ensure a complete and compliant process leading up to it.
AML Must Not Only Improve, It Must Get Faster
The conclusion is clear: AML processes must become faster, not superficially but structurally. The industry is moving from manual workflows to digitally supported process chains.
Institutions that make this shift early will not only reduce their exposure to regulatory sanctions. They will also create conditions that enable their compliance teams to work effectively, efficiently, and sustainably. This is crucial today and will become even more important in an environment increasingly focused on both quality and speed.
If you want to learn what this shift means for your organization and how our AML compliance solution RiskShield can help you meet regulatory requirements, reach out to our experts.
About our Expert
Dr. Stephan Lemkens
Solution Owner Compliance | Risk & Fraud
Stephan has been a consultant within the Professional Services Team since 2018, gaining experiences with projects focusing on Transaction and Session Monitoring in the context of fraud prevention. Since 2020 he has been focusing on Compliance, working closely with our customers on projects around Suspicious Activity Monitoring and Customer Due Diligence.