It’s just compliance. It’s not like we’re saving lives. Kimberly Lacey says she heard that sentiment too many times—including from compliance officers—over the more than two decades she spent building and transforming anti-money laundering (AML) and financial crime compliance programs at major U.S. banks. Her response to those who underestimate the impact of anti-financial crime (AFC) work is simple and swift: “In this discipline, we are saving lives.” 

Lacey was five years into her career as an AML leader at the former SunTrust Bank when the importance of her work snapped into focus like never before. She was at her daughter’s school on September 11, 2010, waiting outside the principal’s office for a meeting about math, when the morning announcements started. “The principal was talking about the normal stuff—what they’re having for lunch, when the PTA meeting is,” Lacey recalls. “Then, he reminded the students it was the anniversary of 9/11.” 

As the principal walked students through a detailed timeline of the terrorist attacks, Lacey said she had an epiphany. “Remembering 9/11, and reflecting on how that day felt, I thought, ‘This is why I’m doing what I’m doing. This is it, right here.’” 

It was top of mind for Lacey that the 9/11 hijackers had used accounts at SunTrust and other U.S. banks to help move and access funds tied to the plot. But she also thought about specific cases she and her team had recently worked on, including uncovering a major human trafficking operation where people were being warehoused and forced into labor. “These are real people. Real lives. It just really hit me hard in that moment that the government would not have known about them but for our SARs,” she says. 

Leading with memories and meaning instead of requirements 

Later that same day, Lacey, a former corporate attorney for SunTrust, was scheduled to brief a group of the bank’s regional presidents on AML requirements and the importance of the institution’s AML, Bank Secrecy Act (BSA) and Office of Foreign Assets Control (OFAC) compliance program. She had the expected talk prepared—“all the lawyer stuff about the law.” But she decided to throw away her speech. 

“I sat at the table with our regional presidents, and we just talked—about 9/11, and about why we’re doing this work,” she says. As they all reflected on the events of 9/11, the bank executives shared with Lacey how it felt when they learned some of the terrorists had used accounts at SunTrust. 

“I realized I wasn’t the only one at the table crying. I was sitting with a bunch of gray-haired men with tears in their eyes,” she says. “That was a real turning point for me, and I don’t think I’ve gone into any meeting about AFC matters since and just talked about the law.” 

A career that began as a detour and became a calling 

Lacey spent 13 years at SunTrust Bank, serving as senior vice president, BSA officer and director of compliance for nearly eight of them. She then led global AML infrastructure and strategy for the compliance function at Citi, overseeing policy, training, SAR programs, testing, communications, and operations across a 2,600-person organization. After that, she joined KeyBank as chief AML officer, where she was tasked with modernizing the AML program, from governance to technology.  

Under Lacey’s leadership, KeyBank’s AML program earned recognition from FinCEN and the U.S. Treasury for surfacing material illicit activity. Lacey also built a special investigations capability that included former FBI, U.S. Department of Homeland Security and Drug Enforcement Administration professionals. 

Now an independent consultant, Lacey looks back at her long and accomplished career in AFC and says she’s still amazed she even ended up on this track. “My vision after law school was to be a corporate lawyer and work on Wall Street. But life took me in a different direction,” she says. 

That pivot occurred in 2005, when Lacey mentioned to a colleague at SunTrust Bank that she was feeling burned out in her corporate law job. “I had two little kids, I was traveling a lot, and working at home late during the week and on weekends,” she says. “I loved my work, but felt it wasn’t sustainable.” 

The next day, the chief risk officer stopped by Lacey’s office to offer her a position on the bank’s small but growing AML team. While her first foray into AFC wasn’t the “nice, quiet compliance job” she had envisioned, Lacey soon realized she’d stumbled into a discipline she felt deeply passionate about.  

She also loved the people. “The caliber of people this discipline attracts are second to none,” Lacey says. “They’re good people who want to do the right thing. They get almost no recognition, but they come in every day and grind through their work—and they do it with a sense of purpose.” 

From laminated sheets to data overload 

Lacey has watched the AML and financial crime compliance disciplines change dramatically over the past two decades, and she’s quick to note that the work has never been simple, even when the tools were as basic as they come. “When I started my career in AML, we used a laminated sheet to risk-rate customers—very high-tech,” she laughs. 

Fast-forward to today and teams have so much data that figuring out what’s useful, understanding connections, recognizing when patterns change, and responding proactively has become only more difficult. That’s why Lacey pushes back when people assume AFC work is a mechanical process where you can simply work through a list of steps and obvious red flags to catch everything that matters. 

“Bad guys don’t walk into banks waving their arms saying, ‘Hey! Bad guy, right here,’” she says. “They don’t announce themselves, and they look like everyone else.” Criminals evolve, context shifts, and the financial and regulatory systems aren’t designed to make the full picture easy to see. “Surfacing suspicious activity and knowing it’s illicit is hard—often unnecessarily so,” says Lacey. 

The “train wreck” of beneficial ownership for privately held companies 

If there’s one structural constraint Lacey thinks the industry still hasn’t fully confronted, it’s beneficial ownership. “Beneficial ownership in the U.S. is a train wreck,” she says. For privately held companies, the primary source of ownership information is often the company’s own books and records, which are rarely accurate or current.  

“As a recovering corporate lawyer, I can tell you unequivocally that 90% of my clients’ corporate books and records were out of date,” she says. “That’s not because they were doing something nefarious, but because they’re busy running their company.”  

That’s why Lacey is blunt when responding to people who ask why banks often “miss” the signs of suspicious activity: “You’d have to be omniscient.” Sophisticated criminals don’t concentrate their activity in one place, either. “Smart bad guys don’t put all their eggs in one basket,” she says. “For investigators, it’s like trying to solve a 10,000-piece jigsaw puzzle where each bank has three pieces.” 

The road ahead: fewer silos, less duplication, more shared truth 

Lacey doesn’t sugarcoat what in-house AFC teams are up against. They’re expected to spot patterns no single institution can fully see and to be right every time. “We’re basically having to fight this battle blindfolded and with earplugs, with our feet tied together and our hands tied behind our back,” she says. 

Still, Lacey is optimistic that the industry can and will continue to improve through the use of stronger tools, including artificial intelligence (AI) and natural language processing, and through better structure as well. She points to the promise of cloud-based, end-to-end AML capabilities that put context first by connecting disparate data into a single trusted view, surfacing hidden relationships, and helping investigators spend less time gathering information and more time making decisions.  

More than anything, though, Lacey would like to see the industry move toward a consortium-style approach that reduces duplicative work and helps AFC teams see more than their own slice of the puzzle. She says a consortium could help create “a singular truth”—a shared picture on the movement of money, where and to whom, that no individual bank can assemble alone.  

“If we can pull it all together, we’ll be so much more efficient and effective,” Lacey says. “Otherwise, we’ll continue to struggle.” 

That bigger-picture view matters even more when major events can change the world overnight, and financial activity previously seen as “normal” takes on new context. When Russia invaded Ukraine, for example, Lacey says her team at KeyBank stopped every transaction involving Russia and manually reviewed “every single transaction, every alert, every case—SAR or no SAR.” It meant late nights and weekends, but the goal was simple: to see what they weren’t seeing. 

A more connected model for information-sharing could help the industry move faster in those moments to surface what has changed and understand why and what it means. That’s why Lacey bristles at the idea that AFC work is “just compliance” with no meaningful impact on people’s lives. 

“You’re stopping the Ponzi scheme stealing the life savings of elderly people,” she says. “You’re stopping a major drug trafficking operation, or a terrorist act before it kills people. You have the ability to get in there and really protect people.” That, in Lacey’s view, is the human side of AML and financial crime compliance: people doing difficult work, under significant constraints, with an unwavering focus on helping real people on the other side of every case.