A white paper from Kharon on the need for AML modernization to address Treasury's call to action

Sep 25, 2025

Company Update, White paper, AML

Kharon Releases White Paper Supporting Urgent Need for AML/CFT Modernization

Kharon today announced the release of a new white paper, The Case for Urgent AML/CFT Modernization. The paper builds on Treasury’s recent call for fundamental reform of the AML/CFT framework.

In remarks at ACAMS Assembly, Under Secretary for Terrorism and Financial Intelligence John Hurley underscored the urgent need to move beyond rigid, low-value compliance practices and toward outcome-driven measures of effectiveness.
While Treasury has laid out the broad objectives of modernization, this paper offers practical insights from years of working closely with global banks on strengthening capabilities related to high priority national security issues.

Key recommendations include:
  • Replacing outdated box-checking with outcome-driven measures of effectiveness.
  • Embedding high-quality open-source intelligence into transaction screening, monitoring, and customer due diligence.
  • Integrating export controls compliance as a core national security priority.
  • Providing categorical exemptions and risk-based relief for low-exposure institutions and business lines.
“Every dollar directed to lower-value compliance tasks is a dollar not spent countering fentanyl traffickers, hostile non-state actors, or adversarial military powers. AML/CFT modernization is both urgently needed and entirely achievable. Our goal with this paper is to help bridge Treasury’s vision with actionable steps institutions can implement now."

- Howard Mendelsohn, Kharon’s President of Global Business Development and Engagement