Interview: Stefan Delaet on the evolving role of AML teams in today’s digital world

Stefan, tell us: how will capacity and skillset for AML teams evolve in the coming years? Which training and development plans are required for training and upskilling staff?

KBC has built a robust and high-performing AML framework, which has taught us a lot about what’s needed for strong AML management. Efficiency through process and performance management is becoming increasingly important. Effectiveness is also high on the agenda, as criminals are becoming more organised and professional. That’s why AML colleagues need to be flexible and agile in our detection and monitoring, much like in cybersecurity.

We need detective mindsets to identify suspicious behaviours or transactions from the data and systems. Collaboration with stakeholders outside our organisation (such as regulators, FIUs, data and IT teams, our peers and competitors, the police and the justice system) will help us raise our game in the fight against financial crime.

How do digitalisation and technology influence the role of AML professionals?

Digital has become the new normal, meaning that the majority of transactions, onboardings, and client interactions now take place remotely. Because of this shift, AML teams need to be open to digital and IT tools. Machines will be able to process large volumes of information and enhance human capabilities. However, senior expertise will still be crucial for the final assessment, due to increasingly complex regulations and the sheer volume of data. This will require computational thinking, including an understanding of data flows and their logical, or illogical, outcomes.

According to AFC (Anti-Financial Crime) Tech expert Shlomit Wagman, the rise of AI means that more skilled AML professionals will be needed – not less. What is your opinion on this?

I believe what she says is valid. Training and development plans should emphasise continuous learning, combining both theoretical knowledge and practical skills. This includes training on the latest AML software and data analysis techniques, as well as keeping up to date with regulatory changes. Upskilling staff through certifications, workshops, and hands-on training is vital to keep up with the evolving AML landscape.

As I’ve already mentioned, I want to stress that common sense will remain crucial for analysing behavioural patterns and intent. That’s not surprising, as every digital profile reflects a human being. Digital profiles often mirror the physical world, but the interactions occur at a much faster pace. It’s almost like speed dating (laughs).

From an investigation perspective, where do you see the split between a first and second line of investigation in AML? What typical skills are needed for both?

In AML investigations, the first line of defence typically involves the initial alert generation and preliminary investigation. This includes tasks like transaction monitoring, customer due diligence (CDD), and initial risk assessment.

The primary objective here is to detect potential atypical behaviour early and flag them for further analysis. To do this, you need strong attention to detail, basic analytical skills, and familiarity with AML software. First-line professionals need to be adept at recognising patterns and anomalies in transaction data that could indicate money laundering.

The second line of defence, on the other hand, involves more in-depth analysis and decision-making. Findings from the first line are validated, more enhanced investigations conducted if warranted, and decisions made on filing suspicious activity reports (SARs) resp. adaptations in the monitoring approach.

The aim of the second line is to ensure that initial alerts are thoroughly investigated and that appropriate actions are taken based on the findings. To achieve this, advanced analytical skills, critical thinking, sound decision-making capabilities, and a deep understanding of regulatory requirements are essential. The ability to interpret complex data, grasp the broader context of transactions, and make informed judgements about potential risks is key to delivering strong results.

Here, I’d like to reiterate the need for increased trend analysis and information exchange in order to detect early attempts by criminals to bypass our systems. This is very similar to the prevention of cyberattacks. This will help us prepare for a future in which real-time monitoring becomes the norm.

How can companies structure their lines of defence to prepare for future AML challenges?

Regardless of how the division between the lines of defence is structured, it must be clearly defined and aligned with the maturity of each part of the organisation. At KBC, we have gradually expanded the tasks and responsibilities of the first line. In 2024, we even established a Group 1st Line Financial Crime Unit to streamline local standards and scenarios, and to take ownership of the applications. This approach ensures a consistent and effective AML strategy across the organisation, strengthening our ability to combat financial crime efficiently and effectively.

Most financial institutions are still exploring various options to address staffing issues. A recent report from PWC stated that “finding skilled staff is the most important factor for effective AML compliance” and that “more than 90% of the respondents stated that they are planning to increase the AML staff with 10% or more.”

What is your take on various staffing options, like nearshoring, offshoring, outsourcing, automation, augmentation and so on?

The requirements for AML teams are indeed increasing, and your needs will depend on the maturity stage of your organisation. At KBC, we’ve gone through several stages, using all of these options at different points.

Some years ago, we began by reinforcing both lines of defence through upstaffing. This was followed by centralising or nearshoring specific tasks and processes to Centres of Competence. The strong capacity for standardisation within the nearshore centres also enabled us to automate more tasks yet with a human oversight.

In parallel, we started building models and we decided to use AI to enhance rule-based systems, which has reduced false positives and improved efficiency and effectiveness. This set-up offers a best of both worlds for now. It allows people to focus to further enhance the maturity of the AML programme.

Given the fast-changing world and requirements, the demand for qualified people will most likely remain high. With limited resources, organisations have to balance their investments in data, technology, and senior expertise. This will support plug-and-play strategies for dealing with spikes and simultaneously create more room for staff development and smarter ways of working.

In this context, seniority in the second line of compliance becomes a critical success factor. These professionals must bring real-life experience from first line investigations, possess an investigative mindset, and be capable of identifying emerging financial crime trends. Organisations should invest in targeted training programmes, external hiring, and internal mobility to make sure the second line is staffed with individuals who can challenge, guide, and elevate the first line. Their expertise ensures that both human and augmented resources are not only compliant but truly impactful. Senior second line experts act as strategic enablers, ensuring that the AML framework remains agile, effective, and future-proof.

At the end of the day, good AML management must be, or become, efficient and effective.