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Blog entry by Delwyn Mathews

The AML Officer Who Followed a Feeling: A Story About Modern Compliance Work

Every AML Compliance Officer has that one moment, the moment when something small, almost invisible, nudges their instincts. For Mara*, it was a late afternoon transaction pattern that didn’t “feel” wrong... but didn’t feel right either.

It wasn’t the biggest transaction she’d reviewed that day. It wasn’t even flagged by the system. But there was something about the timing and the rapid account movements that made her pause.

This is the part of AML work that rarely makes it into job descriptions:
the quiet intuition that grows after thousands of hours spent listening to the rhythm of legitimate business and noticing when something breaks the beat.

The First Step: Curiosity Before Suspicion
Instead of rushing to escalate, she did what effective AML officers often do she started by asking small questions:

Is this normal behavior for this customer? Does the activity align with past trends? Is there a logical business explanation?

She checked historical patterns, reviewed onboarding details, and took a deep breath before drawing any conclusions. AML work isn’t about assuming the worst it’s about patiently understanding the story behind the numbers.

This initial phase curiosity often prevents unnecessary escalations and helps officers distinguish between human error, operational quirks, and potential financial crime.

Technology Can Flag Risks But Humans Connect the Dots
In Mara’s case, the system had overlooked the activity because each transaction fell within expected ranges. Automated tools are powerful, but like most professionals know, they’re also literal. They see data points. Humans see meaning.

AML officers connect those dots identifying unusual combinations that algorithms might skip because they lack context, nuance, and real-world interpretation.

As highlighted in industry analyses, human-machine collaboration is considered the most effective model for detecting evolving risks (Reference: Basel Institute on Governance – Insights on Human Factors in AML).

Engaging the Team Without Creating Alarm
Instead of sounding an alarm, Mara spoke casually with a colleague in the operations department. No accusations. No assumptions. Just a simple “Have you noticed anything unusual related to this client’s activity recently?”

That conversation revealed information not visible in the systems recent changes in the customer’s behavior that warranted a closer look.

This is the human side of compliance:
communication, collaboration, and a shared sense of responsibility.

The Turning Point
A few checks later, it became clear that the activity needed escalation not because of a large amount, but because of inconsistencies that didn’t align with the customer’s known profile.

She documented everything carefully and transparently, not out of fear of penalties, but because accuracy preserves integrity.

In the end, her caution led to an internal review that prevented a potential misuse of the platform. The issue was resolved quietly, professionally, and without disruption.

And no one outside the compliance team ever knew how close they came to a serious problem.

Why This Matters
AML is often viewed as a technical field rules, systems, legislation, procedures. But seasoned officers know that the heart of compliance is human behavior:

- The behavior of customers
- The judgment of the officer
- The culture of the organization
- The willingness of employees to speak up

Even guidance from global bodies emphasizes the importance of understanding human behavior and maintaining effective communication channels (Reference: FATF – Risk-Based Approach Guidance).

Reference: tealcompliance.com

DisclaimerContent posted is for informational and knowledge sharing purposes only, and is not intended to be a substitute for professional advice related to tax, finance or accounting. The view/interpretation of the publisher is based on the available Law, guidelines and information. Each reader should take due professional care before you act after reading the contents of that article/post. No warranty whatsoever is made that any of the articles are accurate and is not intended to provide, and should not be relied on for tax or accounting advice.

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Contributor

Delwyn Mathews (CAMS)
Business Development Manager at IntelleWings | Anti-Money Laundering Specialist

Delwyn Mathews is an AML/CFT specialist with over 6 years of experience in business development, compliance solutions, and operations management across the UAE and India. Currently leading business development at IntelleWings, he helps organizations strengthen fraud detection, streamline KYC/CDD, and enhance regulatory compliance. A Certified Anti-Money Laundering Specialist (CAMS), Delwyn combines expertise in sales, project planning, and data analysis with a strong focus on financial crime prevention and compliance technology.


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