Articles
Lessons Learned from 15+ Years in AML and Financial Crime Prevention
Long-form reflections on what works, what does not, and what the next decade of financial-crime prevention in Spain will demand.
Published 3 June 2026 · by Andréas Hobbelin
What I have learned
- Controls fail where ownership is unclear, not where technology is missing.
- Most false positives are data problems disguised as model problems.
- The best AML programmes are run by people who understand both operations and law.
- Real-estate AML is where the biggest practical gains in Spain are still available.
- Supervisors reward institutions that are honest about their gaps.
What the next decade demands
- Higher-quality data, not more alerts.
- Reusable digital identity as the default for KYC.
- ISO 20022-grade payment context for monitoring.
- A genuine shift from compliance as paperwork to compliance as engineering.
- More cross-sector collaboration between banks, FinTechs, real estate and regulators.