As criminal elements move at machine speed, FinCrime operational models must adapt.

The case for managed services The cost of stayingstuck in the past Financial institutions are investing more infinancial crime (FinCrime) compliance than atany point in history, yet they continue to fallfurther behind. Criminals innovate faster thanbanks can respond; real-time payment rails, More effort ≠better outcomes $10b AML penalties globally 2025 In 2025 alone, anti-money laundering(AML) penalties exceeded $10 billion,with US regulators driving much of theenforcement.1At the same time, traditional The shift to real-time paymentshas raised the stakes further Volumes and values on networks such as RTP and FedNowhave surged,3while authorized push payment fraud, muleactivity and synthetic identity schemes scale at machinespeed. Legacy batch-processed FinCrime programs simplycannot match this velocity. Meanwhile, the human capital at the exact moment when criminals scale and real-timepayments eliminate any margin for delay or error. For financial services leaders, the choice is no longerbetween outsourcing and building in-house; it is betweena model that can scale with modern FinCrime and onethat cannot. The institutions that move first to a managedservices model will reclaim investigative capacity, reduce The conclusion is unavoidable: Running FinCrime operationsentirely in-house has become a strategic liability. It yields 3“RTP’s Instant Payment Volume Nearly Doubled in 2024,”PaymentsJournal website, www.paymentsjournal.com/rtps-instant-payment-volume-nearly-doubled-in-2024/, January 13, 2025. 4“How to increase financial crime analyst capacity without increasing headcount or burnout,”WorkFusion website,www.workfusion.com/blog/how-to-increase-financial-crime-analyst-capacity-without-increasing-headcount-or-burnout/, August 24, 2023. The harsh reality:in-house models are While institutions continue to expand their FinCrimebudgets, the operational foundations of in-house programsare weakening in ways that incremental investment cannotfix. The core issue is not simply rising volume or regulatory Despite sizable compliance spend, even global banks withsignificant resources continue to fall short of regulatoryexpectations. Record high settlements in recent yearsunderscores that conventional internal programs, evenwhen mature and well resourced, are struggling todemonstrate sustained effectiveness under modernsupervisory scrutiny. This reflects a broader trend: A major driver of this inefficiency is the fragility ofthe human capital model underpinning most in-houseoperations. Analysts shoulder repetitive, high-volumeinvestigative work, driven largely by noise rather than risk. of 2% to 3%, which disproportionately affect specialized functions that dependon retained expertise and continuity. The end state is a fixed-capacity operationthat cannot flex when payment volumes surge, typologies evolve or regulatory Complicating this further is the fact that traditional alert-centric monitoringsystems are fundamentally misaligned with today’s threat velocity. Manybanks still operate with as much as 95% false-positive rates.6These legacyrules engines generate overwhelming queues that divert investigator attention At the same time, regulatory expectations are expanding faster than internalteams can adapt. Supervisors and regulators globally are formalizing whatrobust, risk-based AML and countering the financing of terrorism (CFT) programsmust demonstrate: stronger governance, rigorous documentation and moredynamic responsiveness to emerging risks.7,8Even where outsourcing is allowed, Taken together, these forces reveal an in-house paradigmthat cannot scale, cannot stabilize and cannot evolve at the 6“Silencing the Noise: Effective Strategies for Reducing False Positives in Transaction Monitoring,”NICE Actimize, https://resources.niceactimize.com/wp-content/uploads/2024/11/aml-reducing-false-positives-in-transaction-monitoring-brochure.pdf, November 2024. 7“Anti-Money Laundering and Countering the Financing of Terrorism Programs,” Federal Register,https://www.federalregister.gov/documents/2024/07/03/2024-14414/anti-money-laundering-and-countering-the-financing-of-terrorism-programs, July 3, 2024. 8“FinCEN Issues Proposed Rule Requiring Financial Institutions to Maintain ‘Effective, Risk-Based’AML Programs: Six Things to Know,”Covington & Burling LLP website, https://www.cov.com/news-and-insights/insights/2024/07/fincen-issues-proposed-rule-requiring-financial-institutions-to-maintain-effective-risk-based-aml-programs-six-things-to-know, July 3, 2024.“Guidelines on outsourcing arrangements,” European Banking Authority, https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/internal-governance/guidelines-outsourcing-arrangements, revised 2019 (current). Criminals scaled fasterthan banks could respond FinCrime as a service These pressures collide with the rise of real-timepayments. RTP transaction value nearly doubled to$246 billion in 2024, exceeding one million paymentsper day,