The regulatory environment surrounding financial crimes in the U.S. is entering a new era, characterized by a significant increase in enforcement actions and the incorporation of advanced technology. As we move into 2025 and beyond, U.S. banks are facing a rapidly evolving landscape marked by steep penalties, complex compliance demands, and more sophisticated criminal methods. This article explores the key developments that will influence financial crime prevention strategies and how banks are adapting to these challenges with the help of emerging technologies.

1. Record Enforcement Actions Set New Standards for Penalties
The regulatory landscape is undergoing a transformation, with enforcement agencies adopting a more aggressive stance toward non-compliance. The largest penalty in the history of the Financial Crimes Enforcement Network (FinCEN) was handed down in October 2024 when TD Bank was fined $1.3 billion for “chronic failures” in its anti-money laundering (AML) program. This landmark penalty sets a precedent for future actions and signals the severity of the consequences for failing to meet AML standards.

Other notable actions include the Federal Reserve’s fine of $43 million against Silvergate Bank for inadequate transaction monitoring in July 2024, and the Office of the Comptroller of the Currency (OCC) imposing a cease-and-desist order on Bank of America in early 2025 for its failures in meeting Bank Secrecy Act (BSA)/AML requirements. The regulatory agencies are clearly signaling that institutions must establish strong internal controls, appoint qualified AML officers, and consistently comply with regulations to avoid such penalties.

2. Corporate Transparency Act Changes and New AML Program Rules
The Corporate Transparency Act (CTA) will undergo significant changes in March 2025, with the new rules reducing compliance burdens for U.S. companies. While U.S. businesses will no longer need to report their beneficial owners, foreign-owned companies will remain under the microscope due to their higher risk of money laundering. Alongside these changes, a long-awaited rule under the 2020 AML Act is progressing, which would require all financial institutions to maintain “effective, risk-based” AML programs that incorporate regular risk assessments and integration of government priorities.

Further broadening of AML requirements is expected with a new rule set to take effect in January 2026, which will extend BSA obligations to include SEC-registered investment advisers. This shift is part of a broader trend to increase regulatory coverage beyond traditional banking sectors, creating a more inclusive and stringent compliance environment for financial entities.

3. Sanctions Enforcement Remains Strict Despite Fewer Cases
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has maintained a strict enforcement framework regarding sanctions violations. Although the total number of enforcement cases dropped in 2024, penalties remain substantial, especially in violations related to Iran and other geopolitical hot spots. Even with fewer enforcement actions, OFAC’s strict liability model persists, making it clear that companies cannot claim ignorance of sanctions requirements.

Financial institutions are expected to implement up-to-date screening systems to ensure compliance with the latest OFAC lists and sanctions changes. The Treasury Department’s guidance in early 2025 regarding Iran, Syria, and Russia sanctions underscores the fluid nature of compliance obligations and the need for real-time monitoring.

4. AI-Driven Fraud Becomes a Major Threat
The rise of artificial intelligence (AI) and deepfake technologies has revolutionized the landscape of financial crime, creating more sophisticated fraud schemes. The use of AI in phishing campaigns and Business Email Compromise (BEC) attacks is on the rise, with cybercriminals employing AI to mimic executives’ voices and even produce convincing deepfake video calls. These threats highlight the urgent need for banks to implement advanced authentication systems and behavioral analytics to detect fraudulent activity before it causes significant damage.

AI-driven account takeover fraud is also escalating, particularly on platforms such as mobile wallets, P2P payment systems, and cryptocurrency exchanges. Banks are now facing an urgent need to invest in more effective fraud detection and prevention tools, as synthetic identity fraud is projected to result in $23 billion in losses annually by 2030.

5. The Role of Real-Time Payment Systems in Fraud Risk
With the introduction of real-time payment systems like FedNow, Zelle, and RTP, fraudsters are now able to execute scams more rapidly than ever before. The FBI’s 2024 Internet Crime Report highlights the rising number of frauds that exploit these faster payment systems, with criminals manipulating employees into authorizing fraudulent wire transfers. The resurgence of traditional check fraud is another growing concern, as criminals leverage AI to create sophisticated counterfeit checks.

Furthermore, elder financial abuse is increasing, with AARP reporting $28.3 billion in annual losses from scams targeting seniors. These scams often use AI-generated communications to build trust, making it essential for banks to focus on protecting vulnerable populations from such schemes.

6. Cybersecurity Threats Are on the Rise
Financial institutions are facing increasingly complex cyber threats, including new strains of ransomware such as BianLian and Play. Nation-state actors, particularly from Russia and North Korea, continue to target U.S. financial services through cyberattacks, including attacks on cryptocurrency networks and SWIFT systems.

Phishing attacks, fueled by AI technologies, are also on the rise, with over 40% of organizations reporting increased phishing activity. As cyber threats evolve, banks must prioritize third-party risk management and conduct regular security assessments to ensure their defenses remain robust against these ever-changing threats.

7. Technology Solutions Enhance Compliance and Fraud Prevention
To cope with the growing compliance demands and emerging fraud risks, financial institutions are increasingly turning to AI and machine learning (ML) technologies. These advanced tools help banks identify complex money-laundering patterns, reduce false positives, and improve the efficiency of transaction monitoring. Blockchain forensics platforms are also helping institutions trace cryptocurrency transactions to ensure compliance with anti-money laundering regulations.

Biometric authentication and RegTech solutions are accelerating in popularity, with automated customer risk assessments and sanctions screening systems offering banks more efficient ways to manage compliance without increasing headcount. These technologies are essential for maintaining effective programs in an environment of heightened regulatory scrutiny.

Conclusion
The landscape for U.S. banks in 2025-26 is shifting dramatically, with regulatory enforcement becoming more stringent and criminal activities becoming more sophisticated. As financial institutions face these challenges, adopting advanced technologies, updating compliance frameworks, and involving leadership in compliance oversight will be crucial to maintaining resilience and meeting regulatory expectations. With evolving rules, from the Corporate Transparency Act modifications to expanding AML obligations, it is more important than ever for banks to stay proactive and strategic in their approach to financial crime prevention.