Implementing anti‑money laundering (AML) technology is rarely a plug‑and‑play exercise. For law, accounting and real estate firms preparing for Tranche 2, the stakes are high: technology needs to work seamlessly, staff need to adopt it and clients need to cooperate.
Yet many AML tech projects stall or underperform because firms underestimate the cultural, operational and client‑facing challenges involved.
Here are 11 common reasons AML tech projects fail, and practical ways to avoid them.
1. Not bringing your people on the compliance journey
The most sophisticated AML platform won’t succeed if your people don’t use it. Staff who feel blindsided or see AML as a tick‑box exercise often avoid new processes, create workarounds or revert to old habits.
How to avoid it
Bring your people along from the start. Explain the “why” behind AML obligations, not just the “what” they have to do. Involve frontline staff early, appoint team AML champions, and run demos, Q&A sessions and practical training. Embed compliance into job descriptions and KPIs, automate reminders, and recognise adoption to reinforce new behaviours.
2. Doing too much, too early
Trying to implement every rule and process immediately is a common mistake. Overloading staff leads to resistance and frustrates clients, making adoption harder.
How to avoid it
Phase your roll-out. Begin with core client due diligence (CDD) for high‑risk cases, then expand gradually as confidence and capability build. A staged approach creates quick wins and reduces early‑stage friction.
3. Not appointing an executive sponsor
Without a visible leader championing the project, momentum fades quickly. Staff need to see that AML is a firm‑wide priority backed by decision‑making authority.
How to avoid it
Appoint a partner or director as the AML sponsor, and ensure they actively support the project. Their endorsement and accessibility signal that compliance is non‑negotiable.
4. Unprepared clients
Clients often feel surprised or even suspicious when asked for highly personal information without warning. This can lead to delays, pushback or complaints.
How to avoid it
Communicate early and often. Before go‑live, explain why AML checks are required, that these obligations are industry‑wide, and how client data will be protected. Provide clear, step‑by‑step instructions to make the process feel secure and professional.
5. Poor client usability
Even cooperative clients will struggle if your technology is confusing or requests the same information multiple times. Poor usability creates friction and risks abandonment.
How to avoid it
Provide branded, easy‑to‑follow instructions, and collect all required information through a single secure digital channel where possible. Test usability with different client types—especially older clients, remote users and those with accessibility needs—before firm‑wide rollout.
6. Tacked‑on tech
Adding AML software on top of existing processes without rethinking workflows leads to “shadow processes”, unused systems and inconsistent adoption.
How to avoid it
Start by mapping your current client onboarding workflow. Identify your designated services and risk appetite, then redesign workflows to embed AML steps efficiently. Integrate the new technology into your existing systems to avoid duplication and confusion.
7. Misaligned tech to your AML operating model
Technology that doesn’t fit your firm’s operating model creates constant friction. Centralised, decentralised and hybrid models each have very different workflow and approval requirements.
How to avoid it
Decide your operating model first, then select technology that aligns with it. Configure user access, approval paths and reporting to match the way your firm will manage AML end to end.
8. No phased roll-out or pilot testing
Going live across the whole firm in one step is risky. It overwhelms staff, increases errors, and undermines confidence in the project.
How to avoid it
Start small. Pilot the solution with one team, service type or office first. Gather feedback, refine processes, and then scale gradually across the firm.
9. Lack of proper project resourcing
AML projects need more than software—they need time, budget, people and authority. Without proper resourcing, projects stall and adoption lags.
How to avoid it
Secure a partner or director sponsor, appoint a dedicated project lead with protected time, and lock in a defined budget. Maintain a shared project plan with realistic timelines to keep everyone aligned and accountable.
10. Policies and procedures not updated
If your official policies don’t match the new system, staff will fall back on old habits—creating process gaps and compliance risk.
How to avoid it
Update your policies and procedures in parallel with your technology rollout. Communicate the changes firm‑wide before go‑live, and spot‑check usage with new starters or external testers to ensure procedures are followed consistently.
11. Lack of risk mitigation plans
Even the best projects encounter bumps. Without clear risk management, unexpected glitches or client pushback can derail your roll-out.
How to avoid it
Map out likely risks—such as integration failures, user errors, client confusion or scope creep—and define response steps for each. Assign clear owners for monitoring and escalation, test mitigation steps during the pilot, and maintain a live issues log to adjust quickly.
Turning risk into readiness
AML technology can transform compliance from a burden into a streamlined, auditable process—but only if implementation is done right. By proactively managing people, client experience, workflows and governance, your firm can avoid the most common pitfalls and achieve sustainable adoption.
If you treat AML tech implementation as both a technology project and a cultural change, your team will be positioned not just to comply, but to operate with confidence in a more regulated future.
About First AML
First AML comes from the perspective of both a technology provider, but also as compliance professionals. Prior to releasing, First AML’s all-in-one AML workflow platform, we processed over 2,000,000 AML cases ourselves. Understanding the acute problem that faces firms these days as they try to scale their own AML, is in our DNA.
That's why First AML now powers thousands of compliance experts around the globe to reduce the time and cost burden of complex and international entity KYC. Source stands out as a leading solution for organisations with complex or international onboarding needs. It provides streamlined collaboration and ensures uniformity in all AML practices.
Keen to find out more? Book a demo today!