The 18-Minute Paradox: How Rapid-Fire Global AML Rules Create a Patchwork Criminals Exploit
Only global convergence and a focused strategy can turn regulation from box-ticking into a true weapon against transnational organized crime.
By Garry Clement
OTTAWA — In the fight against money laundering and financial crime, regulators around the world are in constant motion. To put it into perspective: on average, every 18 minutes somewhere on the globe, a new financial crime regulation, rule, or guidance is issued or amended.
This staggering velocity reflects governments’ attempts to keep pace with criminal innovation—cryptocurrency abuse, sanctions evasion, trade-based laundering, and AI-enabled fraud schemes, to name just a few. But the sheer volume and frequency of these changes are producing unintended consequences: overwhelming compliance teams, straining enforcement agencies, and creating patchwork approaches that criminals exploit.
For financial institutions, this means compliance professionals must navigate a perpetually shifting terrain. A regulatory update in Singapore in the morning might be followed by a sanctions list change in the EU by afternoon, and a new FinCEN notice in the United States before close of business. Each requires rapid interpretation, impact assessment, and integration into internal systems.
For regulators and law enforcement, the challenge is equally acute. Constant amendments can dilute focus, spreading thin the already-limited resources needed for meaningful oversight. Worse still, global inconsistency means that criminals can identify weak points, laundering illicit funds through jurisdictions with slower uptake or lighter enforcement.
The irony is that while the intent of continuous updates is to close loopholes, the speed and volume of change may itself create new vulnerabilities. Compliance becomes a box-ticking exercise, with organizations more concerned about avoiding regulatory penalties than effectively combating crime.
What must change?
Convergence over proliferation. Instead of constant, fragmented changes, regulators should work toward harmonized international standards that reduce complexity and inconsistency.
Technology-enabled oversight. Both regulators and institutions need to invest in AI-driven compliance tools that can ingest and interpret new regulations in real time.
Outcome-focused regulation. Shift from prescriptive rules to performance-based frameworks that emphasize actual risk reduction, not just process compliance.
The fight against financial crime cannot be won by sheer regulatory volume. It requires smarter, more coordinated, and more sustainable approaches. Otherwise, while regulators race ahead writing new rules, criminals will continue finding new ways to stay two steps ahead.
Here’s the hard truth: if the system keeps changing every 18 minutes, but criminals keep winning, it’s not the rules that need to change—it’s the way we think about them.
Former senior RCMP officer Garry Clement consults with corporations on anti-money laundering, contributed to the Canadian academic text Dirty Money, and wrote Canada Under Siege, and Undercover, In the Shady World of Organized Crime and the RCMP
Too much red tape over thinkers with the rules and laws allows criminals to overtake our justice system. We need black and white laws with no grey areas to try and get a handle on crime. Governments are too busy trying to criminalize law abiding citizens rather than going after organized crime.