AML Transformation  ·  Innovation Advisory

The obstacle to
better AML isn't
the technology.

More than a decade redesigning transaction monitoring inside three global banks, in the First Line of Defence, under regulatory pressure. The question is never whether change is technically possible. It is whether the institution is ready to make it.

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Dan Margetts

Track Record

28+ Years in financial services
3 Tier 1 global banks: HSBC, Nordea, ING
3,000+ FTE across TM transformation programmes
1LoD First Line of Defence specialist throughout

Published

GCFFC: FAQs on the Use of AI to Fight Financial Crime →
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What I do

AML expertise built
on doing the work.

Most institutions that need to improve AML already have a clearer picture of where they want to get to than they tend to acknowledge. The harder problem is navigating the path: the regulatory constraints, the governance barriers, the operational risk of changing controls that supervisors have already accepted, and the internal resistance that surrounds all of it.

Dan works with institutions and senior leaders at that level of the problem, drawing on direct experience of leading that journey at HSBC, Nordea and ING.

01

Innovation & Strategy

Helping institutions design the future state of AML: what intelligence-led, behaviour-based transaction monitoring looks like for this bank, in its risk context, with its current constraints. Drawing on deep regulatory knowledge and direct experience of what it actually takes to move from rules-heavy legacy controls toward something that works better.

02

Transformation Leadership

Senior interim and advisory roles in the First Line of Defence, where the mandate is to make real change happen. Whether stabilising a function under pressure, redesigning core controls from the ground up, or building the governance and operating model that makes sustainable AML possible. The work is in the detail as well as the direction.

03

Thought Leadership

Co-author of the 2024 GCFFC FAQ on AI in financial crime, covering explainability and operating model implications for financial institutions. Developer and owner of ING's Future of TM strategy. Strategic lead at TMNL. Regular speaker on AI adoption, TM transformation and the emerging regulatory framework under AMLR Article 75.

How this work connects

Transformation succeeds
through people.

Every successful AML transformation has one thing in common: at some point, the people involved had to think differently about risk, about what adequate compliance looks like, and about what it takes to build something better. Technology, governance and operating models all matter. But they follow from that shift, they do not create it.

Coaching and transformation leadership share the same core skill: helping people develop the clarity and confidence to act on what they already know. Dan's coaching practice is not a separate pursuit from his AML work. It is the same capability applied at a different level.

Dan is completing the Professional Certificate in Executive Coaching at Henley Business School, a rigorous, externally assessed programme leading to accreditation by the ICF, EMCC and AC.

Dan Margetts
"Leading transformation in any organisation is all about helping people to see things differently. The coaching practice and the AML work are the same challenge at different scales."
Dan Margetts, CAMS

Executive Coaching

Explore the coaching practice  →
Credentials

Track record

Three institutions.
One consistent direction of travel.

2012 – 2016

HSBC

Senior Programme Manager  ·  SVP AML Compliance Operations  ·  Global Head of FCC Operations Enhancements

  • Redesigned transaction monitoring investigation processes, governance and quality frameworks across a global operation of more than 3,000 FTE spanning the US, India, China and Mexico, following a Deferred Prosecution Agreement and under intense regulatory scrutiny.
  • Managed capacity ramp up across FinCrime operations in major offshore centres including in India, Mexico and China, while designing and implementing advanced automation to manage cost escalation and shift investigator behaviour from rules-driven execution toward risk-based judgement.
  • Took direct operational responsibility as SVP AML Compliance Operations in Delaware, US: stabilised a 300+ FTE investigations site, used it as the pilot for global TM standards, and increased capacity by 30 per cent without additional headcount.
  • Acted as a senior subject-matter lead supporting engagement with US regulators and the independent Monitor.

2016 – 2018

Nordea

Head of TM Development  ·  Master Business Developer, TM Innovation  ·  Analytics, ML and Cross-border Team Build

  • Built and led a cross-border TM development and analytics team spanning six countries, responsible for scenario design, risk modelling, validation and control enhancement.
  • Led the first production deployment of machine learning within Nordea's TM function, introducing formal model validation and governance disciplines alongside the new capability.
  • Designed new end-to-end TM development frameworks explicitly linking risk assessment, typology evolution, threshold testing and validation into a coherent control lifecycle.
  • Began the institutional shift from rules-centric monitoring toward behaviour-informed, analytics-supported AML controls that continued through subsequent roles.

2019 – 2026

ING & TMNL

Global Financial Crime Transformation Lead (1LoD)  ·  Interim Head of Transaction Monitoring  ·  EMEA and Global Business Lines

  • Defined and led ING's global Future of TM strategy, establishing a clear direction away from rules-heavy legacy monitoring toward behaviour-driven, intelligence-led detection.
  • Designed end-to-end TM operating models, covering detection approach, investigations, governance, data and MI.
  • Wrote global standard TM investigation and QA procedures and led the consolidation of retail TM operations into a new centre of excellence in Warsaw, ensuring controls were both operationally workable and regulator-credible.
  • Represented ING as strategic lead in TMNL, contributing to the design and governance of Europe's pioneering multi-bank analytics collaboration and helping translate public-private partnership ambitions into practical AML value for the bank.
  • Served as Financial Crime regulatory impact lead for the Digital Euro and as Interim Head of Transaction Monitoring during a key leadership transition.

Earlier roles

EY (2018 to 2019) Senior Manager, Regulatory Compliance. Supported development of EY's global Transaction Monitoring managed services proposition and technology offerings for TM and CDD.
HSBC (1999 to 2012) Programme Manager and IT Director roles across UK, USA, Canada and Mexico. Global programme management of HSBCnet, HSBC's international internet banking platform. Implementation of internet banking for HSBC Mexico.
Earlier career Commercial real estate development and consultancy in London and Moscow. Chartered Surveyor (ARICS). Director of H+H Internet Marketing, advising firms on early web technology adoption.

Thinking

Where the industry is going
and what it will take to get there.

Dan's perspective

The case for intelligence-led AML

Rules describe what criminals did last time. AI-based detection can identify what they are doing now. The regulatory architecture is catching up: AMLR Article 75 creates the legal basis for the kind of cross-institutional intelligence sharing that TMNL and similar initiatives have been building toward. The constraints slowing this transition are not technical. They are organisational, commercial and political. That is where the interesting work is.

Current focus

March 2024

FAQs on the Use of AI to Fight Financial Crime

Published by the Global Coalition to Fight Financial Crime. The sections on AI explainability and the operating model and skills implications for financial institutions were Dan's primary contributions. A practical framework for institutions thinking through what responsible AI adoption in AML actually requires, beyond the technology itself.

Industry Publication  ·  GCFFC Read the publication  →

Get in touch

This work begins
with a conversation.

Whether you are working through what the next generation of AML controls looks like for your institution, exploring what it takes to get there, or looking for senior advisory input on a transformation programme, the first conversation is usually worth having.

Schedule a call transformation@danmargetts.com

Email

transformation@danmargetts.com

Book a call

zeeg.me/danmargetts/lets-build

LinkedIn

linkedin.com/in/danmargetts

Based

Amsterdam, Netherlands  ·  UK citizen

UK and EU engagements. Dan has worked extensively across the Netherlands, UK, Sweden, USA and Canada, and is experienced in navigating multi-jurisdictional regulatory environments.