As we reach mid-2025, significant changes to the U.S. anti-money laundering (AML) regulatory landscape are taking effect—impacting private lenders, financial institutions, and compliance officers nationwide. At Geraci LLP, we believe staying ahead of these developments is critical to maintaining regulatory compliance and protecting your business.
What’s Changing in AML Compliance in 2025?
The Financial Crimes Enforcement Network (FinCEN) has introduced sweeping updates aimed at modernizing and strengthening AML and Countering the Financing of Terrorism (CFT) programs. These reforms reflect the evolving nature of financial crimes and the need for more effective risk management.
- Mandatory Risk-Based AML/CFT Programs
Financial institutions must now implement robust, risk-based AML programs tailored to their specific risk profiles and customer base. This approach prioritizes resources on areas of greatest vulnerability.
- Integration of National AML Priorities
Institutions are required to align their compliance programs with FinCEN’s national AML/CFT priorities—updated every four years to reflect emerging threats such as cybercrime, terrorism financing, and corruption.
- Periodic Risk Assessments
Conducting formal, periodic risk assessments is now a regulatory requirement. These assessments evaluate the institution’s business activities, customers, and geographic exposure to ensure AML efforts are appropriately focused.
- Board-Level Oversight and Approval
AML programs must be approved and overseen by the board of directors or an equivalent governing body, increasing accountability at the highest organizational level.
- Independent Testing and Employee Training
Regular independent testing of AML programs and ongoing employee training are mandated to ensure effectiveness and adaptability to evolving risks.
- Expanded Scope of Covered Entities
The definition of financial institutions subject to AML rules has expanded to include more entities, such as registered investment advisers, increasing the compliance responsibilities for a broader range of firms.
Why These Changes Matter for Private Lenders
Private lenders, especially those involved in real estate financing, must recognize that AML compliance is no longer just a box to check—it’s a critical component of risk management and regulatory adherence.
Failing to comply can result in severe penalties, reputational harm, and even criminal liability. Additionally, robust AML programs help prevent your business from inadvertently facilitating money laundering or terrorist financing.
How Geraci LLP Can Help
Navigating the complexities of AML compliance in 2025 requires specialized legal expertise. Geraci LLP offers tailored guidance and support to private lenders and financial institutions, including:
- Comprehensive AML program development and risk assessments
- Board education and compliance strategy consulting
- Assistance with independent testing and employee training programs
- Regulatory review and enforcement defense
Our team stays current with the latest regulatory developments to help your business stay compliant and secure.
Stay Ahead in 2025
The AML landscape is rapidly evolving. Ensuring your private lending operations meet these new requirements will protect your business and enhance your reputation.
Contact Geraci LLP today to discuss how these 2025 AML updates affect your lending practices and how we can help you implement effective compliance solutions.
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