AML and Financial Crime Recruiters

The Financial Crimes Enforcement Network’s Year in Review for fiscal year 2024 states that FinCEN receives reports from approximately 324,000 registered financial institutions and other e-filers. Suspicious Activity Reports were 4.3 million in FY2022, 4.6 million in FY2023 and 4.7 million in FY2024, an average of 12,870 SAR filings a day in FY2024. Currency Transaction Reports in FY2024 were 20.5 million. FinCEN states that ten filing institutions accounted for approximately 45 percent of all FY2024 SARs. The infographic says that all statistics in it are approximate. Fiscal year 2024 is 1 October 2023 through 30 September 2024. A hiring plan that treats 4.7 million as a calendar-year 2025 figure, or as a count of open roles, has misread the label.

The same infographic keeps an enforcement line that must not be mixed with later cases. FinCEN issued 2 civil money penalties in FY2024, with a combined value of $3,400,100,000. It also states that in November 2023 FinCEN assessed a $3.4 billion civil money penalty against Binance. November 2023 falls inside FY2024. The $3.4 billion is the agency’s description of that settlement. It is not a third penalty to add to the $3,400,100,000.

TD Bank is the next year. On 10 October 2024, after FY2024 had closed, FinCEN assessed a $1.3 billion civil money penalty against TD Bank, N.A. and TD Bank USA, N.A. for Bank Secrecy Act violations, and imposed a four-year independent monitorship. FinCEN described that assessment as the largest penalty against a depository institution in U.S. Treasury and FinCEN history. The same day, the Justice Department announced guilty pleas. TD Bank agreed to forfeit $452,432,302 and to pay a criminal fine of $1,434,513,478.40, a total financial penalty of $1,886,945,780.40, and to retain an independent compliance monitor for three years. The Justice Department stated that TD Bank had separately reached agreements with the Federal Reserve, the OCC and FinCEN. The $1.3 billion and the $1,886,945,780.40 are two agencies’ resolutions announced together. They are not a sum, and neither is part of the FY2024 penalty total of $3,400,100,000.

The monitoring fact is the one that decides who gets hired. The Justice Department’s case page states that TD Bank excluded categories of transactions from automated monitoring such that 92 percent of total transaction volume went unmonitored from 1 January 2018 to 12 April 2024, a gap of approximately $18.3 trillion. A BSA officer search opened because of that resolution is a remediation seat: scenarios, a lookback, a monitor, and the person who will sit in front of the examiner. It is not a greenfield program at a payments firm that has never filed. Those are two requisitions. Writing both into one description is how the clock slips.

Homeland Security Investigations, in the same FY2024 review, conducted approximately 290,000 queries related to BSA reporting. That is a measure of how law enforcement uses the filings. It is not a measure of how many compliance lawyers changed jobs. The counsel seat exists because someone at the institution decides what to file, and what the scenarios will catch, before that query is possible.

One US rule moved the other way, and it should not be staffed as if the 2024 build-out were still the job. On 26 March 2025 FinCEN published an interim final rule that narrows beneficial-ownership reporting under the Corporate Transparency Act to foreign reporting companies. Domestic reporting companies, and US persons as beneficial owners, are exempt. FinCEN’s questions and answers on that rule state that a foreign entity that became a reporting company before 26 March 2025 had to file an initial report no later than 25 April 2025. A counsel hired only to stand up domestic beneficial-ownership reporting is not, by that project, a BSA officer. The two got fused in job descriptions during 2024. The March 2025 rule split them again.

Banks and credit unions hire against the examination, not against a generic compliance cycle. FinCEN’s figure that ten institutions filed approximately 45 percent of FY2024 SARs is the concentration in the filing system. The other approximately 324,000 registered filers are the long tail: community banks, credit unions and smaller institutions whose BSA officer is often one person. The 10 October 2024 resolutions are the remediation market at the other end: FinCEN’s four-year monitorship and the Justice Department’s three-year monitor are different undertakings. Do not write “the monitor” as if they were one appointment. The industry page is commercial and retail banking. Counsel who will sit in New York or Charlotte still have to be able to explain a scenario that was switched off. The compliance market those firms draw from is compliance and regulatory recruiters in New York.

Payments and money transmitters hire when the SAR decision has outgrown the operations manager. The daily file is MSB registration, state licenses, and the corridor that generates the alerts. Their volume does not appear as a line in the FinCEN year in review, and no public series gives a headcount of their lawyers. The tell is a bank partner, or a state examiner, asking for the governance memo behind a filing policy. Those seats are usually counsel under an existing general counsel, or a BSA officer who is not the chief compliance officer. The sector page is payments and money transmission.

Crypto and crypto-asset service providers are a third bench. AMLA’s 2025 work, and the 10 July 2027 application of Regulation (EU) 2024/1624, put CASPs inside the EU regime on a published timetable. A US platform still has a BSA program, a Travel Rule question, and a sanctions screen that is not the same document. A markets lawyer who has written a token opinion has not, by that opinion, tuned a monitoring scenario. The sector page is crypto and digital assets. We do not treat a product counsel as a substitute for the officer who has filed.

UK authorized firms hire an MLRO when the FCA review, not a US consent order, is the document on the table. The annual report’s finding that up to two-thirds of more than 300 corporate finance firms were non-compliant with the Money Laundering Regulations is a 2025/26 supervision result. The £42 million Barclays outcome in July 2025 is an enforcement result about customer due diligence. The 1 September 2025 failure-to-prevent-fraud offense is a board result for large organizations, and it may sit with the general counsel rather than the MLRO. Three documents, three possible seats. The officer search is sanctions, MLRO and AML recruitment. A chief compliance officer who owns financial crime among other regimes is chief compliance officer search.

Law firms hire when those companies will pay for advice they no longer want to invent in-house, or when a partner’s book has outgrown the associates who can staff a lookback. The assessment is the matters signed: examinations, monitorships, SAR lookbacks, skilled-person reviews, and whether the portable work is BSA, an MLRO practice, or a sanctions practice wearing an AML title. A matter that has already been charged belongs with white-collar crime and internal investigations. A matter that is still the program belongs here. Lateral partner search is partner recruiting. The bench under the partner is associate recruiting. Washington is where the agency practice concentrates; the compliance practice in that market is compliance and regulatory recruiters in Washington. Firms are for law firms.

Interim is the sixth category and it is not a discounted permanent search. A lookback that must start before a permanent officer is in the chair, or a sudden vacancy while a monitor is in the building, needs someone who can work this month. Interim and fractional engagements are counted separately from the 400+ placements (230+ in-house): 60+ delivered since 2017, with a median of 7 days from first call to start. Days billed are credited against a later retained fee. The service is interim legal talent. Companies briefing the permanent seat and the interim cover at once should say so at the start.

Sartori & Partners was founded in 2017. Since then the firm has completed 400+ placements (230+ in-house). Of those, 87 are senior and specialist in-house counsel, and 36 are compliance and regulatory leadership. AML and financial-crime hires into companies sit inside one of those two groups, depending on the seat, and they are not an additional total. The map we recruit from is 1,480,000+ lawyers. That figure is the firm’s market map. It is not a census of BSA officers.

On the AML and financial-crime subset, Sartori & Partners has closed 16 searches since 2019. 6 were BSA officer, MLRO or head-of-financial-crime seats and sit inside the 41. 7 were specialist financial-crime counsel and sit inside the 87. 3 were law-firm lateral mandates and sit outside the 400+ placements (230+ in-house). The median on those 16 files is a shortlist in 23 days and an accepted offer in 12 weeks. Across all 87 senior and specialist counsel seats the median is faster: 18 days and 8 weeks. Across the 36 compliance-leadership seats it is 21 days and 10 weeks. The gap on the 16 is the split between a US examination practice and a UK MLRO practice. A requisition that asks one person to be both, and to own OFAC, is how a file slips past that median.

A general counsel search remains a different book even when the general counsel will personally own the first SAR file. Of 52 GC and CLO placements since 2017, the median is 24 days to shortlist and 11 weeks to an accepted offer. Use in-house counsel recruiting when that is the seat. An AML search is the right brief when the hire will own monitoring and reporting under a general counsel who is already in the chair.

One 2025 file sits on the subset median. A state-chartered regional bank in Charlotte hired its BSA officer. The shortlist was on day 23. The accepted offer was in week 12. The company had written a single description asking for a BSA officer, an MLRO and sanctions screening. The search was scoped to the charter that was actually being examined, and to counsel who had sat an examination, which is why it cleared on the median of the 16 rather than past it. That file is one of the 6. It does not reset the 10-week median of the 41.

“The shortlist named people who had sat an examination, not people who had written a policy. We hired the BSA officer in week 12.”

The working method is the same as on any retained company mandate. Week one is the brief: regime, charter or permission, reporting line, whether the seat is the officer or the counsel under the officer, and whether a monitor is already appointed. Mapping follows. Outreach is private. An offer is engineered against the counter-offer a sitting BSA officer can expect, without our publishing a counter-offer rate for this subset. Off-limits: we do not approach lawyers we placed for as long as they stay, and we do not recruit from a client’s legal department for 24 months after a mandate. How that runs in full is on methodology. A company that wants the conversation before a form is at talk.