The AML Playbook for CFOs Eyeing a Cross-Border Payment Upgrade

On the one hand, as digital payment rails proliferate, cross-border optimization has evolved into a growth lever that determines how fast a company can enter new markets, how well it can serve global customers, and how credibly it can partner with banks, FinTechs and regulators.

On the other hand, cross-border workflows have also become a frontline defense against financial crime as data flows become richer. As companies integrate digital wallets, alternative payment methods (APMs) and local clearing mechanisms, the complexity of anti-money laundering (AML) compliance is no longer something finance leaders can outsource or postpone.

For chief financial officers navigating global regulatory environments, or even just those bridging the United States and other regions like Europe or Asia-Pacific, the challenge is not simply complying with one rulebook but designing systems that can satisfy multiple regulators simultaneously.

Cross-border payments sit at the intersection of AML, sanctions, payments regulation and data protection. These regimes are enforced nationally and regionally, but they are increasingly shaped by global standards that expect richer data, faster monitoring and more proactive risk management.

The emerging question facing finance leaders then is how to embed smarter controls and real-time visibility into cross-border flows without slowing the business down or fragmenting the customer experience.

Read also: Cross-Border Payments Become a Strategic Chessboard for CFOs

Why Cross-Border Payments Are an AML Flashpoint

Every cross-border transaction creates a chain of handoffs across banks, payment service providers, wallets and local payment rails. Each handoff in turn can introduce opacity, latency and risk.

“The term ‘cross-border’ signifies that a payment traverses different legal entities, jurisdictions, regulatory frameworks, sanction regimes, and, in [some] cases, FX currency controls [also apply],” Emanuela Saccarola, Citi’s head of cross-border payments, services, told PYMNTS in November. “This introduces additional challenges, including liquidity management, navigating multiple time zones, managing cut-off times and complying with the relevant regulations, which may not always be consistent.”

Criminal networks try to exploit these seams using layering techniques that rely on jurisdictional gaps, inconsistent data standards and slow post-transaction controls. Regulators know this, which is why cross-border payments attract disproportionate scrutiny during examinations and enforcement actions.

The rise of digital wallets and APMs intensifies this exposure. Local payment methods are essential for conversion and customer trust in many markets, but they often rely on intermediaries outside traditional correspondent banking networks. CFOs who view these integrations purely through a growth or cost lens risk inheriting AML blind spots that only surface once volumes scale.

In the U.S., AML obligations are anchored in the Bank Secrecy Act and enforced by multiple agencies, with a strong emphasis on customer due diligence, transaction monitoring and suspicious activity reporting. In the European Union, the regulatory framework is more fragmented but moving toward centralization, with harmonized AML rules, stricter sanctions enforcement and heightened expectations around payment transparency. For multinational companies, this means that a transaction compliant in one jurisdiction can still trigger concerns in another if data fields are missing, counterparties are insufficiently screened or monitoring thresholds are misaligned.

One of the most common mistakes CFOs can make when modernizing their cross-border payments is designing compliance around a single regulator. That approach may work for domestic payments, but it breaks down as soon as money crosses borders. Cross-border compliance is ultimately a cumulative, not substitutive, operation.

See also: How AI and Orchestration Rewired Cross-Border Payments in 2025

ISO 20022 and the Compliance Opportunity in Data

One of the perceived trade-offs in AML modernization is speed versus control. CFOs worry that adding real-time monitoring and screening will slow payments, frustrate customers and undermine growth objectives. In practice, the opposite is often true, with benefits that are increasingly being compounded by the migration to the ISO 20022 messaging standard for cross-border payments.

“It’s a waterfall effect,” Ed Dean, vice president of product at Nuvei, told PYMNTS in October, adding that faster payments provide richer know your customer (KYC) data, which satisfies regulatory concerns internationally. “Faster payments are actually breaking down some of the concerns that we have seen historically through cross-border [commerce] … when we have good secure data, which we have through faster payments, I think over time we’re going to see faster cross-border movements.”

For example, ISO 20022 standardizes and expands the data that travels with each payment, creating a common language that regulators, banks and corporates can all interpret for AML purposes. Names, addresses, purpose codes and intermediary details can be transmitted consistently across borders, reducing the risk that information is lost or misinterpreted at each hop. For CFOs, this translates into fewer payment repairs, faster settlement and lower operational risk.

The key is visibility. CFOs need to understand not just the front-end provider, but the full chain of settlement and custody behind each wallet or local method. Where is money held? Who performs customer due diligence? How are transactions monitored, and against which standards?

The PYMNTS Intelligence report “The Treasury Management Playbook: Spotlight on Cross-Border Payments” found that cross-border payments are more important than ever and that companies are looking to minimize the frictions associated with international transactions.

Ultimately, the AML playbook for cross-border payments is no longer about checking boxes after the fact. It is about designing systems that are intelligent by default, resilient by design, and aligned with global standards that turn compliance into a platform for growth.

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