Guide to successfully implementing AFC systems

Implementing a new anti-financial crime (AFC) system is a complex and large project because of the amount of data required to enable the system and the regulatory expectations for the system’s capabilities and performance. Whether a system is being introduced to replace outdated technology, to meet new regulatory requirements or to enable greater operational efficiency, the process demands significant investment in time, resources and leadership focus.

Despite these high stakes, many financial services organizations encounter similar challenges during an implementation project. Delays, cost overruns and unexpected complexities are common. By anticipating the most frequent pain points and building a plan that mitigates them, financial services organizations can significantly improve their chances of a successful rollout.

The following are five key areas where challenges occur and some practical strategies for successfully addressing them.

Selecting the right vendor

Choosing a best-in-class vendor does not always yield the right solution for an organization. A vendor should be evaluated not only on brand reputation but also on how effectively its platform aligns with strategic priorities, business requirements, risk appetite and the operational environment at the organization.

The system should support scalability, changing business needs and evolving regulatory expectations. It should offer a broad set of features and functionality, integration of internal and external data sources, cloud deployment options and a clear technology enhancement road map that supports the organization’s strategic direction.

In addition to product functionality, organizations should examine the vendor’s implementation track record with similar organizations, particularly focusing on responsiveness, support quality, stability and adaptability to regulatory change. A vendor that can quickly update systems and maintain compliance will be far more valuable in the long run.

Costs factor into the decision―but value should be evaluated against costs. A solution that requires higher upfront investment but delivers fewer false positives, better efficiency and stronger compliance outcomes can often prove more cost effective over time.

The right vendor balances strategic fit, robust functionality and proven performance. Organizations that assess these elements carefully are more likely to choose a system that delivers lasting value and supports growth well into the future.

Stakeholder identification and comprehensive planning

Identifying the right stakeholders across compliance, information technology (IT) and the lines of business is a critical element of a successful implementation. Doing so helps increase organizational alignment and clarify objectives and priorities at the outset. Robust planning is essential to project success. Without it, organizations often face delays, budget overruns, rework and even regulatory scrutiny.

A lack of executive buy-in and unclear ownership are among the most common issues that lead to misalignment between the various stakeholders and vendors. Effective planning should include clearly defined goals, realistic timelines and a shared understanding of responsibilities and expected outcomes. It is also important to anticipate potential risks and establish a communication framework to align stakeholders and vendors throughout the process.

Clearly defining roles and responsibilities can help organizations avoid misunderstandings and misalignment. Senior leadership should provide visible sponsorship, set up the right tone and confirm that adequate resources are allocated and that the project has the authority needed to move forward. Throughout the implementation, communication should be consistent so that stakeholders remain informed and aligned, while project objectives should be communicated to support a shared understanding of the goals and success factors.

Organizations also need to recognize the risks of trying to deliver everything at once. A flashy approach can stretch resources, cause delays and ultimately reduce effectiveness. Instead, a phased approach can be more successful by directing initial efforts toward high-priority, high-risk areas. Early wins can build momentum, and a structured road map helps provide a clear path for the delivery of future phases.

Successful implementation begins with careful preparation and alignment at the organizational level. Testing and tuning should be included in the project plan from the start―not treated as an afterthought. Organizations should define clear objectives, scope and success criteria that are supported by realistic timelines and resource allocations. A comprehensive approach includes system functionality testing, performance tuning and robust data testing to validate quality, accuracy, as well as reconciliation across core, channel and onboarding systems.

Active participation from compliance, IT, analytics and subject-matter experts is important for confirming that testing covers regulatory requirements and operational realities. Planning should also anticipate multiple test cycles, establish communication and documentation processes, and build flexibility for future adjustments prompted by business or regulatory changes.

Comprehensive planning across all stakeholders is the key factor that helps the implementation of projects progress smoothly, avoid costly missteps and satisfy regulatory expectations.

Building a solid data foundation

Data integration is another critical element of AFC system implementation projects. Many of the essential activities that should be completed during implementation are highly dependent on the successful integration of data from the organization’s core, channel and onboarding systems as well as from in-house and third-party data providers. Because of these dependencies, sufficient time should be allocated to planning and executing data-related activities. Failing to identify the right data sources and neglecting to assess data quality are common causes of implementation delays, issues and false positives.

Organizations that underestimate the complexity of data often encounter delays, budget overruns and poor outcomes. A strong data foundation requires careful planning and disciplined execution. Three specific, proactive actions organizations can focus on include those listed below.

• Focusing on high-impact activities: For AFC systems, organizations should prioritize the data required for financial crime use cases instead of attempting to integrate every possible dataset at once. Attempting to include everything can overwhelm teams, delay progress and introduce unnecessary complexity. By starting with the most critical information, such as know your customer data, account information and comprehensive transactional activity including counterparties, organizations can build confidence in the system while preparing to add less critical data later.
• Evaluating data quality: Completeness, accuracy and timeliness of data should be verified before integration. Missing fields, inconsistent formats or delayed feeds can all undermine effectiveness and lead to false positives. Organizations should create plans to deal with incomplete or low-quality data, which might involve remediation, cleansing or implementing workarounds until improvements are made in the source system.
• Planning for data testing: Data quality, accuracy and consistency are critical for reliable outcomes. Testing should validate that data is complete, reconciled across core, channel and onboarding systems, and fit for use in decision-making. Establishing test cases early helps identify discrepancies before they affect downstream processes. Organizations should also consider the scalability of their testing approach and verify that methods can adapt to growth and evolving business requirements.

A phased approach should be considered when integrating data. Beginning with the most important datasets allows the organization to demonstrate early progress, reduce risk and build momentum. In addition, more complex or less reliable sources can be integrated into the AFC platform as the implementation matures.

Building a solid data foundation provides multiple benefits. It reduces the likelihood of costly remediation, improves system output, increases effectiveness and enhances the organization’s credibility with regulators. Perhaps most importantly, a reliable foundation gives stakeholders confidence that the new system is built on accurate information, which increases trust in its outputs and supports broader adoption.

Ultimately, the success of an AFC system is only as strong as the data that feeds it. Organizations that treat data as a core priority from the outset are far better positioned to deliver systems that detect risk effectively, operate efficiently and provide a lasting return on investment.

Model testing and tuning

A new system’s functionality, data and integration will require comprehensive testing to ensure that results are accurate, consistent and aligned with expectations. In addition, the new system’s models and detection scenarios―such as transaction monitoring rules―should undergo preproduction tuning to confirm that thresholds and parameters are set at the right levels and align with the organization’s specific financial crime risks and tolerances. Without this step, even a well-designed system can produce misleading outcomes.

When testing and tuning are not performed thoroughly, organizations often encounter critical issues after go-live, including excessive false positive volumes that overwhelm investigators, missed suspicious activity that creates regulatory risk and failure to meet model validation standards. Each of these issues can erode confidence in the system, frustrate users and lead to costly remediation projects.

To prevent these challenges, organizations should treat testing and tuning as a primary workstream by allocating skilled staff, adequate resources and sufficient time for qualitative and quantitative validation. This effort should include the steps listed below.

• Creating test plans and scripts: Comprehensive test plans define objectives, inputs, expected outcomes and criteria for success. Well-designed scripts lead to consistent testing.
• Conducting system integration and user acceptance testing: System functionality, design and outputs should be tested across all relevant scenarios to identify defects and confirm integration works as designed. Testing includes standard scenarios and edge cases where data quality or system performance might break down.
• Performing preproduction tuning: Thresholds and parameters should be tuned to balance sensitivity with efficiency. Detection scenarios should be tuned so that they are effective at identifying organization-specific risks while minimizing false positives. In addition, all tuning decisions should be documented for audit and validation purposes.
• Documenting and demonstrating transparency: Regulators increasingly expect robust evidence of testing activities and clear justification for tuning decisions. Maintaining thorough documentation of methodologies, results and rationale supports transparency and audit requirements, demonstrating compliance with supervisory expectations.

Taking the time to execute these steps thoroughly is critical to avoiding unnecessary risk and helping the system perform as intended from the start. A disciplined approach to testing and tuning improves system accuracy and builds confidence among regulators, stakeholders and end users that the platform can protect the organization.

Aligning stakeholders and building the right team

A poor implementation experience can set the tone for the entire life cycle of an AFC system. If users are frustrated during rollout, productivity suffers, adoption lags and the relationship with the vendor likely becomes strained. To avoid these outcomes, it is critical to build a team with the appropriate experience and diverse skill sets for a project of this size and complexity.

Implementing AFC systems successfully requires cross-functional collaboration from compliance, risk, technology and operations, as well as clearly defined expertise and expectations from project initiation. Organizations can take several steps to strengthen team structure and accountability, including those listed below.

• Identifying skill sets and resources: The team should include compliance officers, anti-money laundering specialists, data analysts, IT integration experts and project managers. Each role should be matched carefully to the responsibilities that support implementation.
• Setting expectations early: Roles, responsibilities, delivery timelines and escalation paths should be established in advance so that both internal staff and vendors understand how the project will
  be managed.
• Collaborating with vendors: Implementation should be treated as the beginning of a long-term relationship with the vendor. A collaborative and transparent approach helps build trust and sets the foundation for continued success. Progress and quality should be monitored against agreed-upon milestones, with regular reviews to confirm that commitments are met.
• Bringing in implementation expertise: Supplementing the team with seasoned personnel who have completed many implementation projects is key. Consulting specialists with AFC system experience can strengthen delivery discipline, close gaps between the business and IT and support a smoother rollout process.

Aligning all stakeholders and building the right team reduces risk during implementation and positions the organization for long-term success. A well-structured team can anticipate challenges, resolve issues quickly and help the organization maximize its investment. By investing in people as much as technology, organizations can create the conditions for a system that delivers lasting value, strengthens compliance and supports operational resilience well into the future.

Embracing the challenges and opportunities

Implementing an AFC system is both a challenge and an opportunity. Organizations that focus only on technology often stumble. Those that anticipate common pain points, select vendors carefully, align stakeholders, assemble the right teams, build strong data foundations and test thoroughly are far more likely to succeed.

Tapan Shah, CAMS, principal, Crowe LLP, Chicago, IL, USA, tapan.shah@crowe.com,

Elena Sutton, MBA, CAMS, senior manager, Crowe LLP, Miami, FL, USA, elena.sutton@crowe.com,