For some time, we have observed the apparent failures and breaches in the financial regulation within the European and other world financial markets. Moreover, the last several years were full of geopolitical tensions, environmental and regulatory challenges that had a substantial impact on reputational and financial crime risks of Financial Institutions ("FIs"). Regulatory developments towards increasing measures against financial crime, such as (i) an increased scope of enforcement actions, (ii)creation of the new regulator AMLA in the EU and (iii) recently introduced 12^th and 13^th European packages of individual and economic sanctions targeting Russia² are constantly evolving. The use of technologies such as AI also have a tremendous impact on financial crime compliance practitioners and the way how they daily operate. The Fenergo Report states the following: "since the financial crash in 2007, an estimated USD 56.1 bln in enforcement actions has been levied to financial institutions and individuals for AML, data privacy, MiFID, and ESG compliance violations. The global fines for failing to prevent money laundering and other financial crime surged more than 50 percent in 2022, fueling warnings that such penalties are not curbing the behavior and systems flaws that allow criminals to channel money through the global financial system."³
The abovementioned failures of the FIs in adhering to the regulatory requirements were often followed by substantial fines, financial impact and reputational losses. That is why the FIs as one of the main front lines in the financial market must ensure efficiency and efficacy of full scope of their AML/CFT activities to comply with the AML laws and expectations of their regulators.
Further to the Kroll's recent 2023 Fraud and Financial Crime Report⁴ "financial crime is growing, with 69% of participants responding that they think financial crime is likely to become more prevalent over the next 12 months. Among the key factors considered responsible for increased financial crime risk were specified (i) cybersecurity and (ii) data breaches." It can be further anticipated that due to the high level of financial volatility and geopolitical tensions, the financial crime risks will be further evolving and may become a global threat, thus the role and capabilities of the anti-financial crime compliance officers would become more vital and challenging than ever.
This article provides a personal view of lessons learned, challenges and ways forward within the AML compliance banking industry. The aim of this article is to reflect some regulatory and market developments over the last years and to consider future directions and ways forward in evolution of financial crime trends, systems and controls. This article addresses professionals working in the financial sector, in particular, AML compliance officers and financial crime investigators, risk managers, internal and external auditors, quality assurance managers as well as students of banking and financial laws and other fields within the financial markets.

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