In high-quality manufacturing, effectiveness is judged by output rather than intent. A production line is only considered reliable if it delivers consistent results under real operating conditions, supported by clear quality controls and the ability to explain deviations when they occur.

U.S. regulators are increasingly applying a similar, outcome-focused lens to screening programmes. Rather than assessing controls in isolation, they look for outcomes that are timely, consistent, and explainable – three attributes that together create a resilient and defensible screening capability. Optimising one without the others is not just inefficient; it can actively increase compliance risk.

This article explores why each element in the trifecta matters, how they interact, and what the trade-offs look like in real screening environments – particularly under the scrutiny of U.S. regulators.

Why speed matters – but not in isolation

In many parts of the financial system, decisions have been pushed into near real time. Payment rails are faster, customer behaviour is more dynamic, and threats evolve quickly. Screening teams increasingly need to make rapid determinations to avoid disrupting legitimate activity while still preventing sanctioned, illicit, or high-risk flows.

That pressure is accelerating as real-time payment volumes continue to grow rapidly, with instant payment transactions projected to expand at over 35% annually through to the end of 2030 [1], further compressing the time available for screening decisions even further.

U.S. regulators emphasise that screening controls must be both risk-based and effective across their operating lifecycle. A 2024 proposed rule by the Financial Crimes Enforcement Network (FinCEN) to amend the Bank Secrecy Act reinforces this expectation, stating that institutions should maintain effective, risk-based AML/CFT programmes – including screening controls – that focus resources on the highest-priority threats [2].

Timeliness matters because delayed screening decisions can lead to:

• unnecessary holds on legitimate transactions

• frustrated customers and business partners

• missed opportunities to prevent wrongdoing in-flow

At the same time, speed alone does not make a programme effective. Without consistency and explainability, fast decisions can be shallow, defensive, or misaligned with risk. In the eyes of U.S. regulators, speed only adds value when it contributes to sound, defensible outcomes.

Consistency: uniform outcomes reflect disciplined design

Consistency in screening outcomes is a strong signal to regulators that an institution’s controls are well governed. Inconsistent decisions – where similar scenarios lead to different outcomes – often point to gaps in methodology, model governance, or training.

For example, BTC-to-fiat transfers from the same counterparty being flagged at one time and cleared at another without a clear rationale can raise supervisory concerns about calibration, oversight, and governance. Regulators test for this by reviewing documented decision criteria and sampling cases across analysts and time periods.

This focus on consistency is not speculative. Supervisors have explicitly highlighted the importance of the quality and effectiveness surveillance systems, models, processes, and controls, with expectations for increased accuracy and consistency [3]. 

Greater consistency improves programme resilience by:

• reducing operational variability

• enabling repeatable decisions across exam cycles

• building confidence in risk scoring and escalation processes

From a regulatory standpoint, consistency is what turns screening from a collection of individual judgements into a controlled programme. It gives examiners confidence that outcomes are driven by defined risk logic and governance – and it gives compliance leaders a stable foundation for improving speed and explainability without introducing new weaknesses elsewhere.

Explainability: the ‘why’ behind the decision

Explainability is what ties speed and consistency together in a screening programme. U.S. regulators increasingly look beyond what decision was made to examine why it was made, and whether that rationale is clearly documented and capable of withstanding scrutiny from auditors and examiners.

This becomes particularly important as advanced technologies such as machine learning and AI are introduced into screening workflows. While these tools can significantly improve detection performance and decision speed, they also introduce new supervisory questions if decision logic cannot be clearly articulated. Without transparent reasoning, institutions risk challenges around opacity, model risk governance, and accountability.

This focus is reflected in independent research. A 2025 analysis of challenges in AML screening and surveillance highlights growing interest in advanced techniques and technologies, while identifying explainability as a key requirement for screening efficiency.

Explainability matters because:

• regulators expect defensible, well-documented decision paths

• compliance teams must be able to clearly articulate how exceptions and escalations are handled

• explainability underpins effective model governance, validation, and ongoing oversight

Without explainability, improvements in speed or consistency can quickly become liabilities. With it, screening programmes are far better positioned to deliver timely, repeatable outcomes that regulators can understand, trust, and defend.

The trade-offs: why imbalance increases risk

The screening trifecta is not a set of independent boxes to check. Each attribute directly affects the others, and imbalances between them are a common source of screening risk.

• Speed without consistency or explainability: Fast but inconsistent screening decisions can lead to defensive holds or releases, undermining both customer experience and regulatory confidence. When decisions are made quickly but without shared logic or clear rationale, similar cases can produce different outcomes that are difficult to justify after the fact.

• Consistency without speed: A perfectly consistent screening methodology loses much of its value if it takes days to reach decisions. In these situations, institutions are often pushed towards conservative defaults that delay or disrupt legitimate activity, creating friction without proportionate risk reduction.

• Explainability without speed: Highly explainable screening logic that can only be produced after lengthy case reviews introduces its own risks. Backlogs grow, decision windows close, and the programme struggles to keep pace with the real-time demands of modern payments and onboarding.

U.S. regulators recognise these trade-offs implicitly. Examination findings tend to focus on outcomes rather than individual tools, and concerns often arise when programmes are slow, inconsistent, or difficult to defend in practice. 

This outcome-focused approach is reinforced by the aforementioned rule proposed by FinCEN to strengthen and modernise AML/CFT programmes, which also emphasised that controls must be ‘effective, risk-based, and reasonably designed’ to address priority threats – not simply comprehensive on paper [2].

Why this matters now

U.S. regulators are sharpening their focus on the effectiveness of AML programmes, with screening increasingly at the centre of that assessment. FinCEN’s proposed modernisation of AML rules reflects a broader shift towards outcome-oriented supervision, making clear that simply having controls in place is no longer sufficient – programmes must demonstrate that they work in practice.

As the financial ecosystem continues to evolve, this shift takes on greater significance. Faster payments demand speed, but only where decisions remain consistent. Expanding customer networks increase the need for standardisation, but not at the expense of explainability. And as screening decisions become more automated, regulators will look closely at whether rationale keeps pace with velocity. In 2026, these tensions are likely to define how screening programmes are evaluated.

Viewed this way, speed, consistency, and explainability are not separate compliance objectives. Together, they form the lens through which screening effectiveness will increasingly be judged – shaping how programmes are designed, tested, and challenged in the year ahead.