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AML/CFT

AML program productivity: Boost the impact of AML investigations

Mary Ellen Biery
October 30, 2024
Read Time: 0 min
female worker at laptop

Increasing efficiency of compliant AML investigations   

To boost AML program productivity and keep pace with evolving compliance demands, financial institutions should focus on strategic operational improvements paired with the smart use of technology.

Key topics covered in this post: 

Operational improvements & technology can increase throughput

Compliance leaders at financial institutions face growing challenges in enhancing AML program productivity, especially as the volume and complexity of financial crimes continue to rise. While they observe other institutions incurring multi-million-dollar fines for AML-related compliance violations, they themselves must navigate budgetary constraints and difficulty either finding experienced professionals or training newer staff.

What’s a leader to do?

To boost AML program productivity and keep pace with evolving compliance demands, financial institutions should focus on strategic operational improvements paired with the smart use of technology.

Below are 8 ways financial institutions can enhance the productivity of their AML programs and increase the efficiency of case investigators.

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1. Conduct risk-based quality control reviews.

One of the most effective ways to improve the productivity of AML case investigators is by implementing a robust AML quality control framework tailored to your institution's risk profile.

A structured quality control process that includes the regular review of high-risk cases and the timeliness of the institution’s AML reporting can catch inefficiencies early. They can spot logjams in the alert-clearing and investigation process to prevent them from escalating.

Regulators expect an institution to maintain a quality control program for AML activities, said Josh Hawkins, Director of Abrigo’s Financial Crimes Unit. The Federal Financial Institutions Examination Council (FFIEC) BSA Examination Manual directs examiners to determine whether an institution’s controls for assuring ongoing compliance with BSA regulatory requirements include mechanisms to identify compliance deficiencies.

In addition, he noted, a recent consent order from the FDIC required an institution with assets below $1 billion to ‘establish satisfactory quality control procedures over the alert clearing and investigation process. Abrigo Advisors expect this emphasis on quality control will be a theme during exams —even at smaller institutions.

The benefit of quality control efforts that are dynamic is that they can be adjusted based on staffing levels and employee performance to improve overall productivity. For example, a bank or credit union may decide that new employees require quality control on 100% of their alerts during training, while seasoned staff might only need periodic reviews.

2. Enhance staffing strategies with data-driven assessments. 

Deficiencies and inefficiencies are often influenced by staffing issues, and understaffing is a common problem in many AML departments. Simply hiring more staff isn’t always the best solution or one that is necessarily welcomed by leadership, especially given pressures to restrain non-interest income expenses.

An AML staffing assessment can uncover inefficiencies and bottlenecks, or even help leaders identify when workloads have grown beyond what current staffing can handle, Hawkins said. Indeed, a staffing assessment may often be the first step for institutions in in risk-based quality control.

Data-driven staffing assessments will pinpoint where resources are most needed. They can also determine whether short-term or long-term adjustments to staffing are best for addressing deficiencies or inefficiencies. Finally, they provide the data for compliance leaders to make a strong case for additional resources if necessary.

3. Streamline case management processes.

One of the largest areas for improvement in AML programs is case management. As the volume of suspicious transactions increases, banks often respond by hiring more investigators. However, continually adding personnel is not a sustainable strategy.

Instead, institutions should focus on optimizing how existing investigators work, and a focus on case management will help.

One way to streamline case management is by rethinking the triage process. Rather than investigating alerts in the order they are received, financial institutions can implement more structured workflows that prioritize higher-risk cases first. This approach helps ensure that resources are allocated effectively, focusing on the most pressing threats before less critical ones.

Some machine-learning AML systems can also automate the triage process, which helps not only with efficiency but also explainability to auditors and examiners.

4. Leverage automation to reduce manual tasks.

As noted above, automation can play a significant role in reducing the time spent on repetitive, low-value tasks such as analyzing data, gathering basic customer information, and managing case investigations.

Many financial institutions still rely heavily on manual data entry for everything from completing suspicious activity reports (SARs) to reporting. Spreadsheets and manual processes are not only time-consuming but prone to errors. Implementing tools for these tasks can free up investigators to focus on higher-risk cases, improving both productivity and job satisfaction.

In fact, a key finding from Gartner’s 2024 Banker’s Guide to AML Tools for Productivity is that “raising the productivity for your AML workforce by just a few percentage points, within the case management capability, will likely outweigh all the additional license and usage costs paid to the new AML vendor.” 

The firm recommends that banks and credit unions calculate the extent to which a replacement AML system could boost investigators’ productivity, accuracy, and consistency when evaluating any AML system to replace current processes or systems.

Before MidCountry Bank implemented BAM+ AML software, it was using folders on the network, grabbing screenshots, managing Excel documents, and writing lengthy reports for due diligence. “Now, all of that just comes right into the system,” said Pam Carl, the bank’s Chief Risk Officer. “The amount of time savings … is just incredible.”

The bank is also able to file CTR and SAR batches directly to FinCEN, saving time and allowing the AML Officer to continue working while reporting without bogging down the system.

5. Optimize detection rates and accuracy.

Transaction monitoring is often at the core of AML programs, but even when a financial institution has an automated system, many systems generate excessive false positives, overwhelming staff.

“As the frequency of financial crime rises and detection becomes more sensitive, the risk is that the case management function is overwhelmed by the sheer volume of cases to investigate,” Gartner said in its report. “So increases in efficiency and productivity for existing case investigators are absolutely essential for banks that cannot afford to hire ever more new investigators to the point of absurdity.”

Being able to configure AML software to an institution’s unique risk profile while ensuring full transparency into the underlying data gives banks and credit unions the accuracy and precision to reduce false positives. For example, MidCountry Bank immediately slashed the number of false positive alerts and streamlined case management with AML software. “Our alert-to-case ratio has noticeably improved,” Carl said

Banks and credit unions can further fine-tune monitoring parameters for more efficient case management with above-the-line/below-the-line testing. Above-the-line/below-the-line testing is a statistical exercise that provides rigorous analysis to transaction monitoring parameters. The testing identifies the optimal settings for suspicious activity monitoring for a specific institution.

Abrigo’s advisors recommend that financial institutions conduct this testing regularly and after significant organizational changes (e.g., mergers, rapid growth) to keep the system aligned with the institution's risk profile and maximize the effectiveness of the monitoring system.

6. Centralize compliance efforts.

Fragmented, siloed compliance systems lead to inefficiencies and increase the risk of missed suspicious activities. Shared AML case management combines insights from fraud and AML teams, significantly improving coordination and information sharing. Modernizing AML/CFT programs with shared case management also aligns with FinCEN’s emphasis on innovation and streamlining processes.

According to the Gartner study, the top selection criteria for institutions replacing an AML system is a more integrated and comprehensive end-to-end platform. When cases can be managed in a single platform, financial institutions can provide better oversight more efficiently.

7. Tailor training to roles and responsibilities.

According to Terri Luttrell, CAMS-Audit, CFCS, Abrigo’s Compliance and Engagement Director, compliant, efficient AML programs rely on staff who are well-trained and knowledgeable about their specific responsibilities. In fact, periodic training is one of the five pillars for AML compliance.

One-size-fits-all training programs waste time and can leave critical gaps in compliance knowledge. Tailoring your AML training to each role—whether it’s front-line staff, management, or board members—ensures employees have the exact knowledge they need to be effective. Moreover, regularly updating training materials to reflect the latest regulatory changes and trends can help keep your team agile.

8. Consider the cloud for scalability and compliance.

AML systems are increasingly being hosted in the cloud rather than on-premises. Cloud-hosted solutions allow banks to benefit from continuous updates and enhanced compliance, among other benefits. Migrating AML capabilities to the cloud provides scalability, easier maintenance, and the ability to adapt quickly to evolving regulatory requirements. Software-as-a-service makes being on top of the latest set of business rules from a vendor far easier than on-premises solutions that must be updated frequently with patches and upgrades, according to Gartner.

Manage risk more effectively.

Operational and strategic improvements can significantly enhance the productivity of AML programs. Focusing efforts on quality control, data-driven staffing assessments, optimizing transaction monitoring systems, and other actions mentioned here are concrete steps AML programs can take. Implementing automation where appropriate, centralizing AML efforts, and moving systems to the cloud will further streamline processes, allowing your institution to stay compliant with more effective efforts.  
This blog was written with the assistance of ChatGPT, an AI large language model, and was reviewed and substantially revised by Abrigo's subject-matter expert.

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About the Author

Mary Ellen Biery

Senior Strategist & Content Manager
Mary Ellen Biery is Senior Strategist & Content Manager at Abrigo, where she works with advisors and other experts to develop whitepapers, original research, and other resources that help financial institutions drive growth and manage risk. A former equities reporter for Dow Jones Newswires whose work has been published in

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About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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