Confidence from clarity: bank-level financial crime compliance for lenders

For years, many lenders operated under a simple assumption: if customer onboarding was robust, and suspicious cases handled sensibly, that was enough.

Those days are coming to an end. Across Europe, lenders and lending-adjacent firms find themselves judged against the same financial crime compliance expectations as banks… but without the same scale, staffing or infrastructure to support them.

Supervisors expect to see evidence of continuous oversight, not just point-in-time checks. They want scenario-based monitoring, well-documented decisions, and justifications tailored to the business model. For lenders, this is a structural shift.

Many are now reassessing their programmes. Rather than relying on isolated screening or manual reviews, they’re looking to connect monitoring, investigations and documentation — so decisions can be made faster, explained more clearly, and defended more confidently.

A sharper line of questioning

One Salv customer has seen these changes first-hand. They face far more detailed transaction monitoring questions from their local regulator compared to a year ago.

“It’s not enough anymore to say we monitor transactions,” explains the firm’s AML lead. “Now they want to know how. What scenarios we run. Why those make sense for our business. And what we do when something triggers.”

Regulators now expect monitoring aligned to real typologies, tailored to how risk shows up in lending, payments, and alternative finance models.

Onboarding checks alone are no longer enough. Regulators are now pushing for continuous customer base monitoring, alongside robust transaction verification, to ensure risk is identified and managed over time, throughout the customer lifecycle.

Small teams, complex risk

The pressure is intensified by size. Another customer has just five specialists overseeing financial crime across multiple regulated entities.

Each business line has a different risk profile. For example, a payment account is fundamentally different from crowdfunding, where funds flow through projects rather than individual balances. Suspicious behaviour may involve related-party transactions, circular flows, or attempts to legitimise funds via repayments or investments.

Yet every risk exposure must be understood, documented, and controlled consistently. For small teams, that’s a real stretch.

Monitoring becomes the battleground

While onboarding checks remain essential, scrutiny is increasingly focused on how monitoring works in practice.

Many firms still rely on fragmented tools and noisy alerts. This creates two problems:

• Newly sanctioned or risky customers can be missed in the noise
• Teams waste time clearing low-risk alerts

Supervisors want monitoring rules to reflect real-world threats, and for alert-handling to be consistent and auditable.

“They’re asking for a different level of specificity,” an AML lead told us. “It’s no longer acceptable to rely on broad rules and judgement alone.”

The cost of standing still

Failing to adapt has a compounding effect. Manual processes slow investigations and increase workload. Alert fatigue raises inconsistency risk. And when regulators ask for evidence, it’s hard to gather.

For lenders under margin pressure, it’s a balancing act: meet bank-level standards, without slowing the business down.

Most of the risk is in defensibility. It’s not just about acting — but proving your actions were structured, reasonable, and repeatable.

From point checks to continuous oversight

As a result, many lenders are shifting to continuous oversight. Instead of treating screening, monitoring, and investigations as separate, they’re seeking end-to-end visibility across customer and transaction behaviour.

That means:

• Fewer isolated checks, more context
• Understanding counterparties, repayment trends and behavioural signals
• Reducing manual workload by filtering out obvious low-risk cases

Collaboration that shortens investigations

Collaboration is becoming more important too. During sanctions investigations, for example, the ability to securely request or share specific data (like a customer’s date of birth) with another institution can shorten investigations and reduce privacy risk.

By contrast, emails, static forms and slow cross-border channels delay decisions and lack audit trails.

The aim isn’t to eliminate human judgement — but to support it. Stronger monitoring and documentation allows teams to clearly explain why something was (or wasn’t) flagged.

Meeting bank-level fincrime standards as a lender

These pressures aren’t going away. If anything, regulatory expectations for lenders will keep rising as authorities seek consistency across the financial system.

That’s why more lenders are exploring all-in-one platforms that combine screening, monitoring and risk tools with built-in intelligence sharing capabilities — giving them the visibility and defensibility that regulators expect.

Cost is also key. But scalable financial crime platforms don’t need to be expensive. For many lenders, the cost may be lower than hiring one additional full-time employee.

Solutions that reduce manual reviews, surface meaningful risk earlier, and support consistent decisions can strengthen compliance while making life easier for your team.

Those who adapt early will be better positioned to have open, constructive conversations with regulators. If you’re a lender looking for a solution proven at bank-level, get in touch with us today.

In a landscape of rising scrutiny, confidence comes from clarity.

FAQs

Why is financial crime compliance changing for lenders?
Across Europe, lenders are now judged against similar financial crime expectations as banks, but without the same staffing, scale or infrastructure to support them. Supervisors expect continuous oversight, scenario-based monitoring, and well-documented decision-making.

What are regulators asking for now?
Supervisors want monitoring aligned to real typologies, tailored to how risk manifests in lending, payments and alternative finance models. They’re asking more detailed questions about how monitoring works in practice — what scenarios are run, and why they make sense for the business.

What financial crime risks are unique to lenders?
Risk varies by business model. In crowdfunding, for example, suspicious behaviour may involve related-party transactions, circular flows or attempts to legitimise funds through repayments or investments. Each exposure must be understood and controlled consistently.

What challenges do compliance teams at lenders face?
Some lending companies manage financial crime risk across multiple regulated entities with very few people. This makes it harder to document and control risks consistently — especially when each business line has a different risk profile.

How can Salv help lending companies?
Salv’s financial crime platform helps lenders connect screening, monitoring and investigations to improve visibility across customer behaviour and support defensible decision-making. For many, the cost is less than one full-time hire. It’s a scalable way to strengthen oversight without slowing down the speed of business.