Banks push shared risk view as instant payments raise compliance pressure

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Banks and instant payments risk

Highlights

Moody’s highlights that anti-money laundering, sanctions, fraud, and customer due diligence teams increasingly overlap in data needs, requiring more cross-functional risk visibility.
Expansion of instant payments heightens operational pressure as funds move within seconds, demanding real-time risk controls and faster, coordinated decision-making processes among banks.
AI and enhanced technology can connect customer and transaction data across departments, but effective governance is essential to preserve specialist risk responsibilities and ensure timely information sharing.

Cross-functional data becomes a risk priority

As outlined by Moody’s, specialist teams in anti-money laundering, sanctions, fraud and customer due diligence still serve distinct legal and operational purposes, but the signals they use increasingly overlap.

Changes in ownership, unusual transactions or new sanctioned links can affect several parts of a bank at the same time. When those issues are reviewed through separate systems, institutions can end up with incomplete views of the same customer, entity or payment.

That overlap is particularly visible in areas such as beneficial ownership, customer identifiers, relationship mapping and transactional behavior. In lending and other activities, the same information can carry implications for both credit risk and financial crime risk, while also informing fraud, payments and operational teams.

A shared view of risk, however, does not mean merging all specialist functions into one structure. The central requirement is making relevant insights visible across teams so they can apply their own controls and expertise with stronger context.

Instant payments intensify operational demands

The expansion of instant payments is making that coordination more urgent because funds can move within seconds, leaving less time for banks to complete certain checks before execution.

Not all controls work on the same timetable. Some AML reviews can take place after a transaction through monitoring and investigation, while some sanctions checks may require action before a payment is processed, increasing the importance of knowing which controls must happen in real time and which can follow later.

Moody’s said banks already hold large volumes of customer and transaction data, but the challenge is to connect that information in a way that supports faster and more consistent decision-making. Shared data elements, clearer governance, defined escalation paths and reusable capabilities can help institutions use the same information across multiple workflows rather than duplicating effort.

Technology, including AI, can support that shift by identifying relationships, inconsistencies and anomalies across large volumes of documentation. Still, banks need governance and decision-making structures alongside technology so the right information reaches the right decision-maker without removing the distinct responsibilities of specialist risk teams.

In our earlier article on banks’ cyber resilience planning, we covered regulators’ calls for deeper recovery capabilities as AI increases the scale and complexity of cyber threats to critical financial services. We noted the shift from relying mainly on defenses toward end-to-end recovery thinking, including independent “bare metal” recovery options to keep core services running if primary systems are compromised.

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