Web Development
Mobile Development
UX/UI Design
Staff Augmentation
CTO as a Service
Dedicated Team
Low code development
Web Development
Mobile Development
UX/UI Design
Staff Augmentation
CTO as a Service
Dedicated Team
Low code development
Fintech
Feb. 11, 2026
28:00 min to read
Table of Contents
What is AML in fintech?
AML Foundations for Fintech
AML Risks in Fintech Business Models
Building a Fintech AML Compliance Program
KYC, KYB, and Customer Due Diligence in Fintech
Screening and Transaction Monitoring
Technology and RegTech for AML
Balancing Customer Experience and Compliance in Fintech
Fintech and Compliance Costs
Implementation Roadmap for Fintech AML Compliance
Our Approach to Fintech AML and Compliance Projects
Fintech products let people move money quickly. Payments are processed in seconds, onboarding is fully digital, and customers can use financial services without going to a bank. This speed and convenience make fintech appealing, but they also make compliance harder.
Anti-money laundering rules were first made for traditional banks, which had slower processes and in-person checks. Fintech changed this approach. Now, AML compliance in fintech is more than a legal need. It is key to building trust, protecting users, and growing safely.
This guide explains how fintech AML compliance works in 2026, points out the main risks, and shows how companies can build compliance programs that help them grow.
In today’s fintech world, AML isn’t just a separate set of rules. It’s woven right into the product. The same systems that handle onboarding and transactions also take care of identity checks, risk scoring, monitoring, and reporting.
Digital finance makes AML much harder. Automation, third-party providers, API connections, and constant streams of data mean signals come from everywhere — onboarding vendors, payment processors, banking services, blockchain analytics, and more. If the information isn’t consistent or traceable, compliance quickly becomes a guessing game.
That’s why AML maturity now comes down to what actually works day-to-day. In 2026, teams are expected to:
AML also becomes a design constraint during fintech development. Everything from onboarding and account limits to risk tiers, alert systems, and investigation tools depends on how you build your user and transaction flows.
-1770975110228.png)
AML in fintech involves using policies, processes, and technology to prevent money laundering, terrorist financing, and other financial crimes in digital products.
This includes checking customer identities, monitoring transactions, assessing risks, and reporting suspicious activity to regulators. In fintech, these controls are usually built into the product rather than handled manually by compliance teams.
Because most modern financial services operate online and in real time, AML controls must process large volumes of activity continuously.
For fintechs, AML is a key part of your growth story. Strong compliance keeps your payment partners on board, helps you breeze through due diligence, opens doors to new markets, and lets you handle audits without any last-minute panic.
When compliance is weak, problems are clear: frozen accounts, upset partners, long remediation projects, delayed launches, and sometimes even fines or lost licenses. But with a strong foundation, growth is easier. Expanding and launching new products is less stressful because compliance is already part of your process.
The key differences aren’t just about whether a company is a bank or a fintech. They’re about the speed at which things happen and the systems running underneath.
Traditional AML programs were designed for slower, more predictable processes: scheduled reviews, batch reports, and lots of manual work. Many banks are now digital too, but fintechs often take things further: instant transactions, rapid-fire feature launches, API-driven distribution, and a reliance on external partners.
This shift means AML isn’t just a periodic check anymore. It’s an ongoing process. Risk has to be recalculated as customer behavior changes. Monitoring rules need to keep up with evolving products. Investigation workflows must handle growing volumes. And whenever something looks suspicious, teams have to clearly explain both why the alert was triggered and why a particular decision was made.
Before fintech companies choose tools, vendors, or reporting formats, they need a strong AML foundation. This foundation sets out how risks are found, who is responsible for compliance, and how controls are used in daily work.
Without this base, even the best AML technology can become a confusing set of rules that are hard to explain, maintain, or defend during regulatory reviews.
At its core, AML is pretty straightforward: know who your customers are, understand how money moves through your product, spot anything out of the ordinary, and take action when something crosses the line.
The real challenge comes from the scale and speed of digital finance. Huge transaction volumes and instant transfers mean you have less time to spot suspicious activity. That’s why automation is a must, and why strong controls rely on good data, clear decision-making, and actually following through on processes.
Most modern AML rules are built around a simple principle: not all risks are the same. Fintechs aren’t supposed to treat every customer or transaction exactly alike.
Instead, it’s all about understanding where the real risks are. Different products attract different kinds of users, and some types of customers, regions, or transaction patterns naturally carry more risk than others. AML controls need to reflect those differences.
Practically speaking, fintechs run tighter checks and closer monitoring where there’s more risk, and keep things simpler and smoother for low-risk users. This way, compliance is both effective and user-friendly. When it’s done right, a risk-based approach protects the business and keeps things easy for most customers.
Even with all the automation in fintech, people are still at the heart of AML compliance. When everyone knows exactly who’s responsible for what, there’s less confusion and fewer gaps. It also makes it much easier to show partners and regulators who made each decision and why.
In most fintechs, AML responsibilities are a team effort:
When everyone’s role is clear, AML compliance becomes part of the daily routine. Teams know what’s expected, problems get caught earlier, and compliance doesn’t turn into a last-minute scramble before audits or reviews.
Fintech companies rarely deal with just one set of regulations. Some begin in a single market and expand step by step, while others reach users in several regions almost from day one. Even small products can involve cross-border payments, international partners, or users from different countries.
Because of this, AML requirements frequently come from more than one regulator at the same time. Fintech teams need to understand how these rules overlap and how to meet them without building separate compliance processes for every market.
Regional laws may differ, but most are based on shared global principles. Knowing the frameworks helps fintech teams design AML programs that work across markets, instead of rebuilding them for every country.
The table below sums up the main AML frameworks fintech companies usually work with and what they mean in practice.
Framework / Regulator
| Region
| What it covers
| What it means for fintechs
|
FATF Recommendations
| Global
| Global AML and CFT standards
| Sets the baseline for risk-based AML, KYC, monitoring, and reporting across most jurisdictions
|
FinCEN / BSA
| United States
| AML rules for financial institutions and MSBs
| Requires customer identification, transaction monitoring, and suspicious activity reporting
|
AMLD (EU AML Directives)
| European Union
| Harmonized AML rules across EU countries
| Defines KYC, CDD, EDD, and reporting obligations, with local implementation differences
|
FCA AML rules
| United Kingdom
| AML supervision for regulated firms
| Focuses on governance, risk assessments, and ongoing monitoring
|
Local AML regulators
| Other markets
| Country-specific AML requirements
| Often based on FATF, but with local reporting, data, and onboarding rules
|
Most fintech teams do not rebuild their entire AML setup for every country they enter, as that would be too slow and costly. Instead, they use a core AML framework, typically based on FATF principles, and adjust the details to align with each country’s local rules.
The basics stay the same everywhere: know your risks, check your customers, monitor activity, and report anything suspicious. Only the details change from place to place. This way, fintechs can expand quickly without letting compliance slow them down.
On the global stage, it’s the Financial Action Task Force (FATF) that sets the tone for AML. The FATF doesn’t regulate companies directly, but its recommendations end up shaping AML laws and oversight everywhere.
For fintechs, FATF sets the standard. Risk-based compliance, customer due diligence, transaction monitoring, and suspicious activity reporting all come from FATF guidance. Following these principles early makes it easier to work with regulators, banks, and payment partners later.
-1770973763227.png)
In the United States, fintech AML compliance is mainly driven by the Bank Secrecy Act and enforced by FinCEN.
Fintechs that offer payments, wallets, or money transfers are often classified as Money Services Businesses. This means they have clear duties for KYC, transaction monitoring, and reporting suspicious activity. US regulators pay close attention to documentation, internal controls, and personal accountability.
Across the EU, AML rules all start from a common set of Anti-Money Laundering Directives. But each country puts its own spin on those rules, so the details can still vary quite a bit depending on where you’re operating.
The UK takes a similar approach, but with oversight from the Financial Conduct Authority (FCA). In practice, UK regulators look closely at how companies are actually running their AML programs, not just what’s written in their policies. They want to see good governance and ongoing risk assessments in action.
Outside the US and Europe, AML rules can look completely different from one country to another. Some regulators stick closely to FATF guidance, while others take a lighter touch or put their own spin on things.
For fintechs working across borders, this all comes down to one thing: your AML setup needs to bend, not break. Rather than rebuilding from scratch for each new market, most teams keep a flexible core system and just tweak the details to fit local requirements, usually things like onboarding, reporting, or how customer data gets handled.
This approach makes it possible to work across markets without turning compliance into a constant rebuild.
Short takeaway: Most AML rules around the world are based on the same core ideas. Building a solid FATF-aligned foundation and adapting it locally is far more practical than starting over in every country.
Fintech products create new ways to move money, access credit, and store value. At the same time, they also create new AML risks. These risks are not theoretical. Regulators see them every day across payments, lending, crypto, and cross-border products.
What makes fintech AML risk different is not the type of crime, but how quickly it can scale. A weak control in a digital product can affect thousands of users before anyone notices.
Below are the most common fintech business models and the AML risks typically associated with them.
Payments and digital wallets are often the first place where AML risks become visible. These products are built for speed and volume, which makes them convenient for users and attractive for improper use at the same time.
One of the main risks is how easily money can move. Users can top up a wallet, send funds internally, and withdraw them again within minutes. When transactions are split into smaller amounts and passed through several accounts, suspicious activity becomes harder to notice.
Neobanks add one more layer of complexity. They usually combine multiple services in one product: accounts, cards, transfers, and sometimes access to crypto or investments. Each feature creates new ways for money to enter or leave the system, which makes monitoring more demanding.
Because of this, regulators pay close attention to how these products handle onboarding, how transaction behaviors are monitored, and how quickly unusual activity is detected and reviewed.
Lending products bring their own set of AML challenges, which go beyond what you’d find in payments. Here, it’s not just about stopping money laundering. It’s about spotting fake identities, catching fraud, and understanding where loan repayments are really coming from.
BNPL and other alternative lending models are all about speed. Approvals happen quickly, and upfront checks can be minimal. That’s great for users, but it also makes it easier for bad actors to slip through using fake names, setting up straw borrowers, or even running scams across multiple platforms at once.
Repayments add another layer of risk. When money comes back from unknown or high-risk sources, lending platforms might unknowingly help launder funds. That’s a tricky problem, since repayments often blend in with regular customer activity and can easily go unnoticed.
Crypto-related fintechs remain one of the most challenging areas for AML. Even regulated products often interact with external wallets, exchanges, or protocols that sit outside the company’s direct control.
The main risks come from how easily funds can move. This is why teams working on crypto development usually need stronger transaction tracing, wallet risk scoring, and clearer controls around fiat on- and off-ramps.
DeFi products add even more complexity. Transactions may involve smart contracts rather than identifiable institutions, which makes responsibility and oversight harder to define.
In 2026, regulators expect crypto fintechs to demonstrate clear transaction tracing, risk scoring of counterparties, and strong controls around fiat on- and off-ramps. Simply stating that transactions happen “on-chain” is no longer considered sufficient.
Many fintechs operate internationally from an early stage. Cross-border activity itself is not a problem, but it increases complexity and risk.
Higher-risk regions, differences in local rules, and limited data availability make monitoring harder. Regulators pay close attention to how fintechs handle sanctions screening, country risk assessments, and unusual cross-border flows.
In practice, fintechs are expected to apply stronger controls where geographic risk is higher, even if that creates more friction for some users.
Across all fintech business models, regulatory attention in 2026 tends to concentrate on a few recurring themes:
Regulators are less interested in perfect policies and more interested in how decisions are made day to day. Fintechs that can clearly explain their risk logic and show how controls change over time are generally in a much stronger position.
Throughout multiple fintech models, the pattern is usually the same. Risks are not caused by innovation itself, but by how quickly products scale and cross borders.
Payments, lending, crypto, and cross-border products all bring their own AML risks. But regulators usually care about one basic thing: does the company actually understand where its risks come from, and does it adjust controls as the business changes. When a product grows but the risk model stays the same, issues tend to show up very quickly.
Because of this, spotting AML risks is only the first step. The harder part is turning that understanding into a compliance setup that works day to day and evolves together with the product.
Short takeaway: Fintech AML risk is driven less by innovation and more by speed and scale. Weak controls that seem minor early on can escalate quickly as products grow and cross borders.
In fintech, AML compliance isn’t something you tack on later — it has to be baked into the product from day one. The program should support fast onboarding, keep up with frequent changes, and still check every regulatory box as your company grows.
The best AML programs are often the simplest. They’re built around clear responsibilities, easy-to-follow steps, and regular check-ins. Everyone understands who’s in charge, how risks are managed, and when things need to be updated.
Governance is often where fintech AML programs quietly stumble, not because there aren’t rules, but because no one really owns them.
At the very least, fintechs need written AML policies and procedures that lay out how onboarding, monitoring, investigations, and reporting are supposed to work. But what matters even more is that these documents reflect what actually happens day-to-day. Regulators can easily spot when a policy looks great on paper but isn’t followed in real life.
Good governance means AML rules get reviewed regularly, updated whenever products or markets change, and are actually used by the team. Policies should drive real decisions, not just gather dust in a shared folder.
Every fintech needs a clearly named person in charge of AML. It’s a real, functional job.
The compliance officer bridges the gap between new product features, risk decisions, and what regulators expect. They sign off on major changes, oversee monitoring and reporting, and serve as the go-to contact for both regulators and partners.
In smaller fintechs, this role is often combined with other duties. As the company grows, regulators expect this person to have more independence, authority, and direct access to senior management.
AML compliance is not just the job of the compliance group. Frontline staff, operations, product, and even customer support often spot issues first.
Regular training helps teams recognize suspicious activity in their specific product, not just in theory. More importantly, it creates a culture where bringing up concerns is normal and expected.
When teams know who to escalate issues to and are supported when they do, problems are caught earlier and handled more consistently.
No AML setup is ever perfect, especially in fintech, where products evolve at lightning speed. That’s why having outside experts review your program is so important.
Regular audits and testing can catch issues early before they grow into bigger problems. They make sure your controls actually work and that alerts are being reviewed when they should be.
Clear reporting is just as important. When suspicious activity is found, decisions need to be documented and reports submitted correctly. Regulators are usually more understanding of mistakes than of silence or unclear processes.
KYC and KYB are often the first things people associate with AML. In practice, they are only one part of the picture, but a very visible one. By late 2025 and moving into 2026, regulators increasingly look at KYC and due diligence no as a one-time onboarding step, but as an ongoing process tied to real customer behavior.
Industry guidance from organizations like Financial Action Task Force and national regulators consistently emphasizes this shift: knowing who the customer is at onboarding is important, but understanding how they behave over time matters even more.
Digital onboarding is one of the main reasons people choose fintech products. Users expect to sign up quickly, often without talking to anyone. Because of this, identity checks have to be fast, but they also need to be reliable.
Most fintechs use a mix of tools for identity confirmation. This usually includes document scans, biometric checks like selfies, and database lookups. The problem is that mistakes at this stage tend to cause bigger issues later. Fake documents, reused identities, and mass sign-up attempts are still common, especially in fast-growing products.
In 2026, regulators pay close attention to how fintechs handle situations where automated checks are not enough. Poor image quality, mismatched data, or repeated onboarding attempts are all red flags. Passing an automated check alone is no longer seen as sufficient. Fintechs are expected to have clear fallback options, such as additional verification steps as well as manual review, and to explain when and why these are used.
Customer Due Diligence does not stop once an account is created. Regulators increasingly see CDD as an ongoing process, not something that is completed during onboarding and then forgotten.
Practically, this means you have to connect who the customer is with how they act over time. Their transaction patterns, how they use your product, and shifts in their account activity all play into their risk level. Someone who seemed low-risk at first might need a second look if their behavior suddenly changes or their activity ramps up.
Many AML issues happen because CDD stays static. A risk score is assigned during onboarding and never updated, even when behavior clearly changes. Fintechs that frequently evaluate and modify risk profiles are much better at spotting new risks quickly, before they turn into serious problems.
EDD is applied when standard checks are no longer enough. This does not automatically mean rejecting customers, but it does require better understanding and closer monitoring.
EDD is usually triggered because of factors such as:
Reviews from enforcement cases show that regulators expect clear standards for when EDD is triggered and documented reasoning behind decisions. When teams cannot explain why one case received extra scrutiny and another did not, problems arise.
As fintech products expand into B2B use cases, marketplaces, and payment facilitation, KYB becomes just as important as KYC.
KYB focuses on verifying legal entities, understanding beneficial ownership, and confirming the nature of a business’s activities. Regulators increasingly expect fintechs to know who ultimately controls a company and how funds move through its structure.
One frequent challenge is keeping KYB data up to date. Businesses change ownership, restructure, or expand into new activities. Manual KYB processes frequently fail to keep pace with these changes.
That’s why so many fintechs use regular reviews and automated updates. They’ll refresh KYB data on a schedule, say, every 6 to 12 monthsor when something big happens, like an account change, a sudden jump in activity, or expansion into new markets. This keeps risk assessments up to date and accurate as things evolve.
Screening and transaction monitoring is a part of AML where fintech teams feel the real complexity of compliance. On paper, rules and alerts look manageable. In real products, they quickly turn into operational pressure once user numbers and transaction volumes grow.
The main challenge here is not a lack of tools, but making sense of signals without inundating teams or damaging the product experience.
Sanctions and PEP screening usually begins when a user signs up: their information gets checked against official lists, and the system decides whether to approve them. But that’s often where fintechs stop, and that’s where gaps can start to appear.
The problem? Those lists are always changing. New names are added, statuses get updated, and risk profiles shift over time. If you only screen once, gaps start to build up quietly in the background. That’s why regulators and partners now expect ongoing rescreening both on a schedule and whenever something important changes, not just a one-time check at onboarding.
Take politically exposed persons (PEPs) as an example. Just because someone is a PEP doesn’t mean they’re automatically high risk, but it does mean you need to pay extra attention. The real trouble often comes from not having clear, documented rules for how PEPs are reviewed and approved. Best practice is to spell out the decision path: why you approved them, what limits you set, and how often you plan to review their status.
Adverse media checks can feel a bit vague right up until something blows up. News stories, investigations, or public accusations often surface long before anything appears on a sanctions list.
The tricky part is figuring out what matters. Not every negative news mention is a real concern, but ignoring reputational red flags can leave you exposed. Teams need a way to weigh the context, decide what’s important, and document their thinking without blocking users just because their name popped up in the news.
During reviews, the main issue is often not the decision itself, but the lack of explanation behind it.
Simple thresholds are easy to implement, but they age quickly. As transaction patterns change, static rules generate either too many alerts or miss important signals altogether.
Teams that handle this well frequently review their monitoring logic. They look at real usage, adjust thresholds, and remove rules that no longer add value. Monitoring becomes a process that develops alongside the product, not something configured once and forgotten.
An alert by itself does nothing. The real work starts after it appears.
Someone has to review it, understand the context, and decide what action makes sense. That decision needs to be recorded clearly enough that it can be explained later.
Many fintech AML problems come from weak case handling. Decisions are made informally, notes are scattered, and months later no one can reconstruct why a transaction was approved or escalated. This lack of traceability is often more problematic than the original risk.
Let’s be honest: reporting suspicious activity feels awkward for most fintech teams. There’s rarely a clear rule about what counts as “enough” reporting, which only adds to the uncertainty.
But the real key is consistency. Teams need to be on the same page about what tips something into reportable territory, and they need to know exactly how to document those decisions.
If your company can clearly explain its thinking, even the occasional mistake is usually forgiven. But when you can’t explain your decisions, even tiny issues can snowball into bigger problems.
Short takeaway for this section: Effective screening and monitoring is less about detecting everything and more about knowing which signals deserve attention and why.
AML technology in fintech has matured a lot. Most products today already use third-party tools for onboarding, screening, and monitoring. The real difference now is not what tools are used, but how they are connected and understood inside the product.
AI and machine learning are often described as a full solution for AML. In practice, their role is much more limited.
Most fintechs use machine learning to help sort and prioritize signals. It can group similar behavior, reduce alert noise, or highlight unusual patterns. Very few products rely on AI to make final decisions on its own, and that is usually a good thing.
The main risk comes when teams treat AI results as final answers. A risk score without a clear explanation quickly becomes a problem when questions come from partners or regulators. In everyday work, AI is most useful when it helps people focus their attention, not when it replaces human decision.
Some fintechs also use generative ai integration services for internal workflows, for example to summarize case notes, draft investigation narratives, or help analysts search past decisions faster, while keeping the final judgment with humans.
AML systems live and die by data quality, even if that’s not obvious right away. Missing info, slow updates, or inconsistent data can quietly weaken monitoring before any big problems show up.
Explainability matters in real life. Teams need to review decisions internally, explain them to business partners, and sometimes defend them to regulators. If no one can say why an alert was triggered (or ignored), even the right decision becomes hard to stand behind.
Teams that actually dig into where their data comes from and how it flows through the system run into fewer headaches than those who just keep tinkering with models without tackling data problems at the source.
In most fintech products, AML does not live in a single system. Identity verification, sanctions screening, transaction monitoring, and reporting are often handled by different tools.
API-first architectures make this kind of setup manageable. They let data from onboarding, transactions, and case reviews flow together without a ton of manual effort. But problems crop up when integrations keep growing without anyone clearly in charge.
When data flows are well defined and responsibilities are clear, AML systems are much easier to operate and maintain.
Most teams start by comparing features when picking an AML vendor, but in reality, how the tool works day-to-day matters way more.
Some tools look flashy but create endless work for your team. Others are simple but fit seamlessly into your workflow. The best choice usually comes down to how your team actually operates — not what’s at the top of an industry ranking.
The fintechs that nail vendor decisions usually start small, test things early, and adapt as they go—instead of tying themselves to a complex system too soon.
Short takeaway: In fintech AML, technology works best as a support layer. Decisions still depend on data quality, explainability, and human assessment.
Almost every fintech team runs into the same tension sooner or later. Compliance wants stronger controls. Product teams want fewer steps and faster flows. Users want things to “just work”.
The mistake many companies make is treating customer experience and AML as opposite forces. In reality, most serious UX problems in fintech come not from compliance itself, but from poorly designed compliance decisions.
Onboarding is the first place users really notice compliance. If it’s confusing or slow, you’ll lose their trust right away.
The goal isn’t to get rid of checks — it’s to put them where they make sense. Ask for everything upfront, and people may bail. Ask for nothing, and you’re setting yourself up for bigger headaches down the line.
Well-designed KYC flows usually feel progressive. Basic access is granted quickly, while additional checks appear only when users reach certain limits or behaviors. From a user perspective, this feels logical rather than restrictive.
False positives are one of the biggest hidden costs of AML. They annoy users, overload compliance teams, and rarely improve risk outcomes.
Most false positives come from static rules that no longer match real behavior. Transaction thresholds that made sense at launch become outdated as products grow and users change how they use them.
Fintechs that handle this well treat false positives as a signal, not just a problem. When too many alerts appear, the question is not “how do we review them faster”, but “why are we flagging so much normal behavior in the first place”.
Reducing noise almost always improves both compliance quality and user experience at the same time.
To users, AML can sometimes feel like they’re being watched. For fintechs, though, it’s a must-have.
Most issues pop up in the gap between these views. People are much more willing to share their data when they know why it’s needed and what it’s used for. If requests come with no explanation, they feel invasive. But if you provide context, most users are fine with it.
The best fintech products weave data requests and permissions right into the user experience. They offer clear explanations, set predictable expectations, and show exactly how data will be used. This builds trust long before any compliance issue ever comes up.
Short takeaway: Good compliance design does not slow products down. Poor compliance design does.
AML isn’t a one-and-done job. It’s an ongoing expense that grows as your user base, transaction volume, and reach expand. What really surprises most teams isn’t that AML costs money, but how quickly those costs pile up as the product takes off.
Early-stage fintechs commonly rely on outsourced compliance support. It is fast, flexible, and avoids building a team too early.
In practice, external compliance support typically costs anywhere from $3,000 to $10,000 per month, depending on scope. These ranges vary a lot by region, licensing needs, and transaction volume, so they work best as “starting point” estimates rather than fixed benchmarks.
Problems appear as volume grows. Reviews slow down. Context gets lost. Edge cases increase. At that point, many fintechs hire their first in-house compliance specialist.
A full-time AML or compliance officer in Europe or the US usually costs $80,000-$130,000 per year, depending on seniority and market. In some markets and seniority levels, total cost can be higher once bonuses, legal/accountability scope, and hiring competition are factored in.
More mature fintechs usually end up with a hybrid setup: in-house ownership plus external partners for audits, independent testing, or market growth support.
Tech costs? They’re usually the easiest part to budget for.
Most fintechs start out spending $1,000 to $5,000 a month on AML tools — covering basics like identity verification, sanctions checks, and simple monitoring. As you grow, costs ramp up alongside your API calls, transaction volumes, and data needs.
Mid-sized fintechs can see those costs jump to $5,000–$20,000 a month, especially when you add in things like adverse media screening, full transaction monitoring, and case management tools.
People costs usually outpace tech spending faster than anyone expects. Reviewing cases, handling escalations, internal discussions, and reporting eat up time across compliance, operations, and even product teams. These costs don’t always show up in early budgets, but they’re very real.
Expanding to a new country? That’s another big cost trigger. Every new market brings new rules, extra reporting requirements, and more monitoring, even if your core product doesn’t change.
One of the hardest things to justify internally is whether AML spending actually delivers value.
Raw metrics like number of alerts or reports rarely help. High volumes may signal strong controls or badly tuned rules. Low volumes may indicate efficiency or blind spots.
More useful indicators are operational. How long does it take to review a case? How often do alerts turn into real investigations? Can the team clearly explain a decision made six months ago?
When AML programs work well, costs feel predictable. Reviews follow clear paths. Escalations are rare but meaningful. Product teams are not blocked by uncertainty every time compliance is involved.
Short takeaway: AML costs in fintech usually start small, scale fast, and grow more from people and operations than from tools.
Most fintech teams do not build their AML programs all at once. They grow into them. What works at launch rarely works two years later, and trying to design a “perfect” setup upfront usually leads to wasted effort.
A better approach is to think in stages. Not formal phases, but natural points where risk, volume, and regulatory attention change.
The starting point is being honest about where the product stands.
Some fintechs already operate across borders, while others are focused on a single market with lower volume. These two setups need very different controls, even if the products look similar from the outside.
At this stage, it’s all about practical questions: Who are your users? How does money flow through your system? Which areas are actually monitored, and which get overlooked? Teams that skip this step often end up overbuilding controls for low-risk areas and missing real problems elsewhere.
Once risks are clearer, priorities usually become obvious.
Some issues are cheap and fast to fix. Better rescreening, clearer alert handling, or improved documentation can remove pressure quickly. These changes often stabilize the system.
Other improvements take time. Redesigning monitoring logic or restructuring case management cannot be rushed. Teams that try to do everything at once usually slow themselves down.
The fastest progress usually comes from choosing the right order, not from doing more.
Growth is where AML setups are really tested.
New features change behavior. New countries bring new rules. New partners introduce new expectations. Each change puts pressure on existing controls.
Fintechs that scale smoothly rely on a stable core. Risk assessment, onboarding standards, monitoring logic, and reporting processes stay consistent. Local or product-specific rules are added on top.
This turns expansion into adaptation instead of reinvention.
Key point: AML roadmaps are most effective when they develop alongside the product, not before or after it.
Fintech AML projects often run into problems not because teams overlook regulations, but because compliance is handled separately from the product. Policies are documented, controls are built into tools, and actual user workflows end up disconnected.
At Stubbs, we work to close this gap. We begin by looking at how the product really works — how users sign up, how money moves, and where risks actually show up. Then we match regulatory requirements to the product, rather than forcing general rules onto real systems.
When we handle AML compliance, our first step is to understand the product’s context. What problem does the fintech address? Who are its users? How does money flow through the system?
After that, we review the regulations. This approach helps us prevent adding unnecessary controls that slow things down without improving safety. Instead, we turn AML requirements into clear product decisions — where checks are done, how monitoring works, and who is responsible at each stage.
This way, compliance frameworks become part of the product instead of feeling forced. Finance, product, engineering, and compliance teams all follow the same logic, so everyone moves in the same direction.
Fintech teams often start AML projects at many different points in their journey.
Some teams need help building the basics before launching or expanding, like risk assessments, core policies, and early monitoring. Others already have tools but face challenges with scaling, false positives, or feedback from regulators and banking partners.
Often, the work is ongoing. We review current setups, identify weak spots, and make changes step by step as the product grows. This way, compliance stays in sync with growth and doesn’t become an obstacle.
If your AML setup doesn’t align with how your product actually works, this is often when an outside perspective can help the most.
Key point: AML is most effective when it's built on real product behavior.
For most fintech startups, AML foundations start with a clear risk assessment, basic customer verification, sanctions screening, and simple transaction monitoring. The goal at this stage is not complexity, but clarity. Regulators expect startups to understand their risks and show control, even if systems are still simple.
That depends on where your users are, how money moves through the product, and whether you offer payments, lending, or digital assets. Many fintechs start by following FATF principles and then adapt to local regulators such as FinCEN in the US, EU AML directives, or the FCA in the UK.
Usually earlier than teams plan to. Once transaction volumes increase, adding AML controls becomes more complex and much more expensive. Basic checks and monitoring introduced early are easier to manage and often prevent bigger problems later, especially when banks or regulators start paying closer attention.
KYC is about confirming who the customer is at onboarding. CDD looks at how risky a customer is over time and tracks changes in behavior. EDD is used when the risk level is higher and more detailed checks are needed. In real products, these are not separate processes, but layers that become more thorough as risk increases.
Technology helps most when it reduces manual work, not when it replaces judgment. Well-integrated tools for onboarding, screening, and monitoring lower operational load, reduce false positives, and help teams focus on real risk instead of noise.
Feb. 11, 2026
28:00 min to read