2025 ABA Financial Crimes Enforcement Conference: Executive Summary

Priorities and Innovation in AML and Fraud

The program’s opening three-part general session focused on Priorities and Innovation in AML and Fraud. ABA President and CEO Rob Nichols addressed the state of the industry. One year ago there were lots of regulations, but new leadership has reoriented towards regulatory right-sizing. Bank Secrecy Act (BSA) reform is a priority and banks are being permitted to de-emphasize low-risk threats. The banking industry is looking for meaningful reforms to empower it to direct its finite resources towards keeping bad actors out of the financial system. For instance, Nichols cited the need for common sense reform to the Currency Transaction Report (CTR) $10,000 threshold – unchanged since 1972 – and data collection requirements. A survey of ABA members suggested that 25% of respondents said 25%-50% of their BSA compliance costs went to CTR filings.    

Seen as a positive step to lessen unhelpful reporting, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) clarified aspects of the suspicious activity report (SAR) process in early October 2025 relating to structuring SARs, continuing activity reviews, and a financial institution’s (FI’s) decision not to file a SAR. FinCEN’s Customer Due Diligence (CDD) rule is another onerous area for banks regarding its account rule compared to collecting information at the customer level. Nichols said a revised CDD rule proposal could come in May 2026. As regards stablecoins, Nichols said banks need to know the “rules of the road”, including clarity as to the GENIUS Act. In sum, Nichols emphasized that banks are on the front lines and cannot do it all. A shift is needed from low-risk to real-risk threats so that banks can focus on stopping financial crime in its tracks.