How Wise Could Have Avoided a $4.2m Fine With a 4-Minute AI Agent

Earlier this year, regulators fined Wise $4.2 million for failures in anti-money laundering (AML) controls. The issues fell into two buckets.

First, operational: regulators flagged that Wise didn’t conduct independent AML program reviews frequently enough, given its size and complexity. That’s about governance and cadence.

Second, and more preventable: gaps in due diligence and monitoring. Wise failed to run adequate ongoing checks, and when diligence gaps appeared, they weren’t reliably escalated. Suspicious activity went unreported, leaving the firm exposed.

The Missed Opportunity

On paper, Wise had processes for monitoring and escalation. But in practice:

• Ongoing checks didn’t capture risky shifts in behavior.
• Escalation wasn’t enforced, leaving compliance teams blind to obvious red flags.
• Manual review was overloaded and reactive, not proactive.

The result: predictable gaps that regulators had no trouble finding.

The 4-Minute Fix: An AI Agent for Ongoing Monitoring

With spektr’s Agent Builder, you can design an agent in minutes that takes monitoring from static to dynamic.

Here’s how it looks (we can make this a lot more complex, but for the sake of showing how the AI Agent fundamentally works, I’ve kept it like this):

1. Continuous Monitoring
Track customer behavior in real time. Spot jurisdiction changes, unusual flows, or KYC inconsistencies as soon as they happen.

2. Automated Risk Routing
When changes are detected, the agent routes them down one of three paths:

• Low Risk: Tag it, log it, no immediate action required.
• Medium Risk: Kick off enhanced due diligence automatically, gathering the extra info for verification.
• High Risk: Trigger a Slack notification for compliance to review immediately.

3. Audit-Ready Evidence
Every detection and every action is logged, creating a defensible trail for regulators.

The build time? About four minutes. The outcome? A monitoring system that never shrugs and never forgets.

The Bigger Picture

The $4.2m fine isn’t about the money. It’s about credibility. A payments firm that can’t prove its AML framework works loses trust with regulators, partners, and customers.

AI agents won’t replace governance reviews. But they will close the day-to-day diligence gaps that lead directly to enforcement. That’s where the leverage lies.

Curious about other major AML failures? See how Monzo could have avoided a £21m fine with a 4-minute AI Agent here.