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From the Trading Floor to the Dirty Money Fight

Community banks are vital in the fight against dirty money, but limited resources make the challenge real. Sarah Beth Felix explains why.

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The Fincrime Pulse Report: U.S. Mid-size and Community Banks

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From the Trading Floor to the Dirty Money Fight

Community banks are vital in the fight against dirty money, but limited resources make the challenge real. Sarah Beth Felix explains why.

From the Trading Floor to the Dirty Money Fight

One moment can alter the course of a person’s entire life. For Sarah Beth Felix, that moment was a terrible day—September 11, 2001. The terrorist attacks that shook the world also prompted Felix, like many others, to question her life’s direction. That self-reflection ultimately led her to walk away from a budding Wall Street career and join the fight against dirty money and financial crime. 

Felix was fresh out of college and had just earned her Series 7 license. “I had long dreamed of trading on the floor of the New York Stock Exchange,” she recalls. “Then 9/11 happened, and it changed everything. It wasn’t like I suddenly wanted to go after terrorist financing - I didn’t even know that existed at the time - but that day changed my outlook on what I wanted for my life.” 

She continued her work as a stockbroker for a short time, but found the work unfulfilling. After some soul-searching and consultation from a trusted adviser, she pursued and landed a job running fraud prevention at the world’s largest check processor. It was there that Felix discovered she had a skill set ideal for fraud-fighting. “I learned I have the mind of a criminal, but really good ethics,” she says. 

Felix’s sharp investigative instincts soon had her working alongside federal law enforcement on fraud cases. The exposure gave her a firsthand look at how financial crime operates and introduced her to the world of anti-money laundering (AML). “I’ve never looked back,” Felix says. 

Two ventures with a shared purpose to help strengthen community banks 

After spending several years building her expertise in fraud prevention and frontline AML, Felix went on to lead consulting practices before founding her own firm, Palmera Consulting. Based in Atlanta, Georgia, Palmera Consulting helps banks, fintechs, and payment companies design and strengthen their AML and sanctions programs. The company is bridging the gap between regulatory expectations and the realities of frontline compliance. 

“I love the community bank space because my work can make a real difference there,” Felix says. “These institutions play a vital role in U.S. communities, and yet they’re shrinking at an alarming rate. They are also under-resourced, undervalued, and under-authorized.”  She adds that AML officers at these banks are also pressured to focus on regulatory “checkbox” compliance rather than proactive investigations.  

Felix, whose career path includes service as a community bank’s first BSA/AML officer, understands these challenges deeply. “I am a fierce defender of these professionals because I was one of them,” she says. 

Felix also recently co-founded Acceleron Bank (in formation), where she serves as chief AML officer. Acceleron began as a platform supporting community banks with international payments and is now transitioning into a fully licensed correspondent bank. For Felix, this endeavor is another way to help ensure compliance and risk management are built into the foundation of banking itself. 

AML pro tip: All work should begin “at the ledge of suspicion” 

To succeed at spotting illicit activity, Felix believes AML officers at any size institution must approach their work as she does—with the mindset of a criminal. “You have to start working on an alert at what I call ‘the ledge of suspicion,’” she says. “Always assume the worst, then work backward. Otherwise, your critical thinking and analysis will be clouded by optimism.” 

Disciplined data work is also essential to AML program success, according to Felix. “Without clean, accurate data, you can’t have compliant sanctions and AML functions. Full stop,” she says. Her advice for community banks is practical: “Get super familiar with your data. If you don’t have a modern platform to help you, revert to Excel. Run pivot tables. And don’t just read FinCEN notices - operationalize them.” 

Felix agrees that AI, contextual monitoring and other technology solutions, used strategically, can also help make AML programs stronger. She says her short list of trusted vendors in the AML technology space includes Quantexa. “If an institution doesn’t have technology that allows them to operationalize notices and prioritize alerts, they’re going to be behind the eight ball all the time,” she says. 

However, she cautions against expecting any technology, including AI, to be a cure-all. Her advice to all banks: Treat technology as an enabler, not a shortcut - and keep well-trained people firmly at the center of AML efforts. “AI is only as effective as the humans who train it,” Felix says. “For example, if your analysts are trained to always assume the best of customers, then you’re training the AI to do the same. That’s dangerous.” 

Collaboration, consistency, and an unwavering focus on the mission 

Felix underscores the importance of midsize and community banks forging strong working relationships with law enforcement. She points to IRS Criminal Investigation’s new “CI-FIRST” initiative, which fosters public-private collaboration and encourages open dialogue. “If you’ve filed thousands of SARs and never heard back from federal law enforcement, that’s your sign that something isn’t right,” she says. “Pick up the phone. Get in the room with law enforcement. One conversation can lead to six new SARs.” 

It is Felix’s view that this kind of direct engagement helps banks understand what matters most and ensure their reporting has real impact. She also cautions AML leaders not to let the politics of the moment shape their programs. “Don’t run your AML program based on what you think your next exam will focus on,” she says. “The deficiencies you allow now will catch up with you in the future. Keep tunnel vision on the mission: finding illicit actors and reporting dirty money.” 

What keeps Felix motivated, though, isn’t just the mission - it’s the people behind it. She points to the dedication of AML officers and her own efforts to share free tools, templates, and other resources with them. “I want community banks to win,” she says. “Dirty money is everywhere. But so are people willing to stand up against it. That’s what keeps me going.” 

That mission, she stresses, is about people - both the AML officers tasked with defending institutions and the communities those institutions serve. “I want community banks to win, and I want to be part of the way in which their AML department wins,” she says. “They need a better advocate - someone who talks directly to their AML officers - not to the CEO, not to the board.”

Read our FinCrime Pulse Report to learn more about the challenges facing U.S. mid-size and community banks.

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