Fighting Financial Crime In A Time Of Extreme Deregulation (2025)

It’s not déjà vu all over, again. The first article I wrote as a Forbes contributor was a prediction of what areas of the anti-financial crimes and regulatory compliance job market were going to be hot and not in Trump’s second administration (which I will refer to as Trump II). My authority to make a prediction lies in the fact that I have been a compliance recruiter going on two decades and know what a good compliance culture looks like. I believe I have a knack for reading the recruiting tea leaves and spotting trends early. However, Trump II proved me wrong very quickly (please refer to my last article, “Why Companies Should Still Care About Compliance in Trump 2.0”). I said AML is apolitical and is never targeted, directly at least, by executive orders. I started recruiting in 2008, at the end of George W. Bush’s second term. So that means my career has spanned several conservative and liberal White Houses. The one consistent trend – that I came to believe was more of an American value than a political observation – was that preventing criminals and terrorists from using US dollars was a nonpartisan goal (even during Trump I). I published my article at the beginning of March 2025. Literally, the next day Trump II proved me very wrong. It’s true that you can have too much of a good thing; extreme deregulation is one them.

Extreme Deregulation: The 10 to 1 Rule

Preventing financial crime, terrorist financing, bribery and money laundering is not only a financial institution’s obligation, but it is also a mission woven into the essence of American culture. More often than not, the terrorist or drug kingpin loses at the end of the movie, right? We don’t want the uber-rich and global conglomerates hiding their tax money or bribing a foreign official to get business, right? We don’t want terrorists financing their terror with US dollars, right? I thought these were no-brainers. To beat the bad guys, you take away their access to the most powerful currency in the world. You don’t give them more access. At least, that’s what I thought.

On January 31, 2025, President Trump signed an executive order mandating that for every new regulation, federal agencies need to cut ten existing regulations. During Trump I, the mandate was 2-for-1.[1] Talk about setting a stronger tone the second go-around. Look, this isn’t surprising. We knew this administration was going to focus on deregulation and increasing the efficiency of regulation. Noble endeavors, in my opinion. However, it’s been less than three months since his inauguration, and so much has changed. This is almost deregulation with contempt. I am a compliance recruiter, but – maybe ironically – I can’t stand overregulation. Technically, preventing money laundering and financial crimes isn’t the same thing as regulatory compliance, per se. Companies are required to have AML programs because financial crime is an existential threat to their survival and the integrity of the global financial services market. In addition, fighting financial crime is a value we all hold. In the US, however, we must be diligent of what we consider a hindrance to innovation and growth. Because at a certain point, over-deregulation can just equate to allowing criminals and terrorists the freedom to abuse our system and the US dollar against Americans.

I want to emphasize that I am using this platform to emphasize the importance of supporting financial crime prevention in our country. The term, “compliance culture”, is one of those very important clichés used in the private sector. It describes whether your company embraces compliance (or not) as a business strategy? Culture, being a set of shared values, always starts at the top. If executives don’t embrace those values, no one will. America’s compliance culture is going in the wrong direction. Let’s count the ways that Trump II has established a specific tone. The message is that the government has been overreaching and will now create a laxer regulatory and enforcement environment:

Commutations:

• Four former executives of the parent company of BitMEX, the cryptocurrency exchange, who obviated BSA/AML regulations.[2] This is the first time a corporation has been pardoned.
• Ross Ulbricht, founder of the black-market website, Silk Road.[3]
• Trevor Milton, CEO of Nikola Corporation, defrauded his investors. He donated to the Trump campaign. One of his lawyers represented the Trump Organization and the other is the current US Attorney General’s brother![4]
• Rod Blagojevich, former Governor of Illinois.[5]

Changes to Regulatory Actions, Enforcements, Policies, and the Compliance Culture

• Going forward, FinCEN (the government agency that oversees fighting financial crimes) doesn’t require domestic US companies to report who ultimately benefits and makes profit within these companies. Secretary Bessent recently said the Department of Treasury will not enforce domestic company registration required by the Corporate Transparency Act (CTA).
• The Department of Justice will not enforce the Foreign Corrupt Practices Act, which prevents Americans from bribing foreign officials to obtain business in foreign countries.[6]
• In less than three months, Trump II has stopped at least 54 cases and investigations brought by the Office of Foreign Asset Control (OFAC), the Consumer Financial Protection Bureau (CFPB) and the SEC.[7]
• Secretary Bessent also said he was going to “unleash” the banking sector by scrapping 15 regulations that agencies, such as the IRS and FinCEN, enforce.
• The DOJ is pausing corporate monitorships for companies that have dealt with accusations of wrongdoing.

Republicans Have Been at the Vanguard of the Fight Against Financial Crime

Fun fact: Republicans and conservative administrations created the American fight against money laundering. That precedent has continued for 55 years to this day.

• Richard Nixon signed the Bank Secrecy Act in 1970, which requires banks to detect money laundering. This was directed at fighting the mafia in America.
• Ronald Reagan signed the Money Laundering Control Act in 1986, which focused on the drug wars of the 1980s.
• George HW Bush signed the Annunzio-Wylie Act in 1992 to fight poor AML programs within complexly structured banks, created the Suspicious Activity Report (SAR), and the Bank Secrecy Act Advisory Group (BSAAG).
• George W Bush signed the USA PATRIOT ACT in 2001, which created the modern fight against money laundering specifically around Counter Terrorist Financing (CTF).

I am going to say it, again: I don’t agree with overregulation out of principle. Burdensome regulation often leads to more fees for the consumer. And, at a certain point, complex regulations stifle innovation and the creation of new products and services that help the debanked and underbanked.

Sorry, I am not done, yet. There is a very good chance that Trump II will increase the Currency Transaction Reporting (CTR) threshold from $10,000 to multiples of that – maybe to $75,000 or even $100,000.[8] The HBO show, The Sopranos, can explain why this is important. If you watched the show, there are scenes where Tony Soprano advises his family and partners-in-crime to never take out, transfer or deposit more than $9,999 because the bank would require documentation on where that money came from. That documentation is called a CTR. I, personally, think the $10,000 threshold is too low. However, eight to 10 times that number is way too high and will give mobsters, criminals, and terrorists a lot of leeway. It will lift a heavy burden on banks and AML/BSA Officers and personnel, but it also might decrease the amount of money laundering detected.

This will blow your mind: It’s estimated that banks and financial institutions stop less than 1% of money laundering attempts in the United States![9] What this tells me is that we need to change how we fight the money launderers. It doesn’t tell me that we should stop fighting them altogether. I believe recent policy decisions are communicating that preventing money laundering is not that big of a deal. Furthermore, we cannot stop fighting it because money laundering is not something that happens in a vacuum. Cybercrime, phishing, cyberattacks, and identity theft, for instance, go hand-in-hand with money laundering. Criminals are getting more sophisticated. We should, too.[10]

I am onboard figuring out a more efficient way to fight financial crime, especially if we can do it with less burden on and regulation of businesses. That would be the perfect combination. What is disconcerting is when campaign donors and friends & family have commuted sentences after they have been legally convicted of terrible financial crimes. What message does that send to all the professionals in law enforcement, regulatory bodies, and the private sector who have dedicated their lives to this cause? More importantly, what message is that sending to criminals and fraudsters? I can picture the smiles on their faces. The government should be working with the private sector in this fight instead of giving the impression that fighting white collar and financial crime is not a priority.[11]

How Will This Affect Recruitment?

The cryptocurrency space – exchanges and wallets, in particular – will see an increase in volume after the effects of tariffs become the new normal. There will be an increase in demand for AML, forensic, fraud and compliance professionals with blockchain tracing experience. Cryptos and Fintechs, in general, will be in demand for AML, fraud and compliance analytics experts and technologists. Traditional finance (your conventional banks) will have less demand for AML/BSA professionals, especially with CTA going to the wayside and daily messages from the White House deprioritizing AML enforcement.

If you are an AML and financial crimes prevention professional, the tone coming from the White House is another reason why you should start becoming more comfortable with compliance technology and systems, AI and machine learning tools used to prevent and detect suspicious activity, and data analytics. AML and compliance programs have become more sophisticated through these tools already, and current federal policy changes will only amplify the movement towards more “efficient” and technologically focused ways of staying compliant and fighting money laundering. The two areas of financial crimes compliance that are booming right now, and will continue to do so, are fraud and cybersecurity. Fraud and cybersecurity are existential risks to all companies because they lead to a loss of revenue, reputational risk, and fines. Deregulation over the next two years, at least, is inevitable. We are barely three months into this administration, so it is safe to assume that deregulation might go to the extreme. But we cannot allow the financial services industry in the US to become the new Wild West all over again.

[1] https://www.whitehouse.gov/fact-sheets/2025/01/fact-sheet-president-donald-j-trump-launches-massive-10-to-1-deregulation-initiative/?utm_source=chatgpt.com

[2] https://www.law360.com/compliance/articles/2317566?nl_pk=e40eb4d2-e44e-4b29-8d61-aa9f3a14ee6e&utm_source=newsletter&utm_medium=email&utm_campaign=compliance&utm_content=2025-03-31&read_main=1&nlsidx=0&nlaidx=12

[3] https://www.newyorker.com/news/the-lede/why-trump-freed-ross-ulbricht-the-silk-roads-dread-pirate-roberts

[4] https://www.cnbc.com/2025/03/28/trump-pardons-nikola-trevor-milton-ceo-securities-fraud-electric-vehicle.html

[5] https://abc7chicago.com/post/praise-criticism-president-donald-trump-pardons-former-illinois-governor-rod-blagojevich-commuting-prison-sentence/15893600/

[6] https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/

[7] https://www.citizen.org/news/enforcement-actions-against-over-100-corporations-stopped-by-trump/

[8] https://www.amlintelligence.com/2025/03/news-us-banks-lobby-to-raise-10000-aml-reporting-threshold-to-100000/

[9] https://www.ledgerinsights.com/anti-money-laundering-has-less-than-1-impact-on-crime-at-what-cost/

[10] https://www.bobsguide.com/unraveling-the-intersections-of-aml-and-cybercrime/

[11] https://www.pymnts.com/technology/2025/intels-new-ceo-vows-to-reform-outdated-development-model/