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Agentic AI and the Future of Financial Crime Compliance in the U.S.

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Financial crime compliance in U.S. banking and financial institutions is at an inflection point. For decades, institutions have struggled with unsustainable operating models: labor intensive manual reviews, alert backlogs, endless false positives, and spiraling costs. Financial crime compliance (FCC) functions such as enhanced due diligence (EDD) and transaction monitoring (TM) remain heavily reliant on human labor, even as transaction volumes increase and risks grow more complex. Yet momentum is shifting. Regulators such as OCC and FinCEN are strongly encouraging AI-driven solutions, and institutions recognize that they must engage with modern technology to solve decades- old problems.

Speaking at the Association of Certified Anti-Money Laundering Specialists (ACAMS) Assembly Conference in Las Vegas in mid-September, John K. Hurley, Treasury’s Under Secretary for Terrorism and Financial Intelligence, laid out Treasury’s vision for modernizing the Bank Secrecy Act (BSA) and the system of AML/CFT compliance that underpins it. The Under Secretary noted the coming paradigm shift toward technology-enabled outcomes over information volume, “…if we measure you by how well you objectively deliver what our customers need, rather than by how closely you conform to an examiner’s subjective opinions, it will allow you to apply your experience and creative talent to invent new and better solutions.”

After more than 25 years of building AML and sanctions programs at banks, including JP Morgan, HSBC, Wachovia, and Riggs, conducting major corruption investigations, and founding consulting and regtech companies, I joined WorkFusion about a year ago when I realized that the promise of AI is no longer theoretical. Today, AI Agents are in production and transforming how banks investigate and report suspicious activity and identify and manage high-risk customers.

Trend #1 – How AI Is Reshaping Sanctions Screening & Transaction Monitoring

Sanctions screening and transaction monitoring have long been plagued by inefficiency. False positives consume vast resources, forcing banks to outsource or expand headcount. AI Agents change this approach. They don’t just flag alerts—they adjudicate them as trained analysts would, documenting every decision for regulator-ready audit trails.

Agentic AI clears false positives just like an analyst would, instantly reviewing alerts and escalating only those that matter. This shift eliminates backlogs and allows compliance teams to scale without adding staff. For small and mid-sized banks, digital workers provide a cost-effective way to meet growing regulatory demands while maintaining operational resilience.

Beyond efficiency, Agentic AI modernizes legacy approaches. Old-school robotic process automation (RPA) or machine learning offered incremental gains, but digital workers enable real-time monitoring and immediate execution of complex compliance processes. For example, AI Agents integrate with sanctions screening tools, adjudicate adverse media alerts, and escalate high-risk cases—all within seconds.

Emerging developments include perpetual monitoring, where AI continuously evaluates customer risk profiles, negative news, and events such as changes in ownership. Governance is strengthened through explainable AI, ensuring every decision is transparent and regulator-ready. All this shifts compliance teams from reactive to proactive.

Trend #2 – Balancing Efficiency + Regulatory Expectations

Efficiency alone is not enough; regulators demand governance. Guidance from OCC, FinCEN, the FDIC, and the Federal Reserve emphasizes transparency, auditability, and oversight. Institutions must demonstrate not only that alerts are resolved quickly, but that decisions are explainable and consistent.

AI Agents can deliver both. Efficiency gains are dramatic—customers report doubling throughput and eliminating alert backlogs. At the same time, every adjudication is documented with detailed narratives, providing regulators with confidence in the process. This dual capability addresses the resource constraints many banks face. Instead of hiring armies of analysts, institutions can deploy digital workers that scale instantly while maintaining compliance rigor.

Roles within compliance are shifting. Analysts are no longer buried in volume review; instead, they oversee exceptions, validate escalations, and focus on strategic risk. This evolution aligns with regulatory expectations: human oversight remains central, but AI handles the repetitive work.

The balance is clear: Agentic AI enables institutions to meet regulatory demands while achieving efficiency gains that were once unimaginable.

Trend #3 – How AI Is Changing Traditional Staffing Models

Staffing models in financial crime compliance are being disrupted. Historically, banks expanded compliance teams to manage alert surges, often relying on contractors or offshore labor when volumes spiked. This model is costly, inconsistent, and unsustainable.

AI is changing the equation. By automating Level 1 reviews across sanctions, adverse media, and transaction monitoring, AI Agents free human analysts to focus on investigations, regulatory engagement, and strategic initiatives.

The human effect is profound. Traditional handoffs between Level 1 and Level 2 teams are disappearing. AI Agents are collapsing layers, streamlining decisions, and reshaping org charts. The result? A flatter, faster, more focused compliance function—where humans lead with judgment, not paperwork.

Consider a major U.S. bank piloting digital workers: instead of hiring 50 new analysts to manage sanctions alerts, the bank deployed AI Agents that instantly reviewed every alert, escalating only true risks. Human staff shifted to oversight and case management, improving morale and reducing turnover.

Hybrid teams—human analysts working alongside digital workers—are now emerging across U.S. institutions. This model blends efficiency with expertise: AI handles scale, humans handle judgment. The result is a more resilient compliance function, capable of adapting to regulatory scrutiny and operational demands.

The Future of Financial Crime Compliance

Agentic AI is transforming financial crime compliance in the U.S. by making false positives irrelevant, balancing efficiency with governance, and reshaping staffing models. Institutions that embrace these digital workers gain not only operational efficiency but also regulatory confidence.

The future of compliance is hybrid—humans and AI Agents collaborating to fight financial crime more effectively than ever before.

David Caruso is Vice President of Financial Crime Compliance at WorkFusion, where he helps redefine how financial institutions fight financial crime using AI. With more than 25 years of experience, he has built and led AML and sanctions programs at banks including JP Morgan, HSBC, Wachovia, and Riggs Bank, and has led major corruption investigations as well as founded and scaled RegTech companies. David is a former U.S. Secret Service Special Agent and a graduate of The George Washington University.