The Payments Compliance Stack
The Payments Compliance Stack
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Correspondent banking relationships have declined 30% since 2011 as institutions exited high-risk corridors to reduce financial crime exposure — a strategy that FATF's 2025 updated guidance has called out directly for pushing payment flows into informal channels and making the underlying risk worse. Issue No. 18 examines the compliance economics driving de-risking, why managing risk rather than avoiding it is now the regulatory expectation, and how agent-assisted due diligence changes the cost calculus that made exiting a relationship cheaper than investigating it.
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The Payments Compliance Stack
Fourteen issues of research across five investigative workflows, three governance chapters, and the DOJ's new self-disclosure framework have confirmed the series' central argument: the bottleneck in financial crime compliance isn't detection — it's the investigation workflow. Issue No. 15 takes stock of what held up, what surprised us, and what the industry's shift from experimentation to governed deployment means for the 26 issues ahead.
DOJ's new Corporate Enforcement Policy and SDNY's voluntary self-disclosure program offer a declination — no fines, no monitor — if your institution finds misconduct and reports it before the government does. The compliance investigation workflow is now a criminal liability question, and Issue No. 14 maps the eight-step corporate investigation workflow that makes self-disclosure possible.
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