Strategy, operational efficiency, and the role of the CCO in the digital age

Nicolás Franco
Adriano Mucelli
March 5, 2026

Technology has transformed the financial industry.

In recent years, the ecosystem has grown exponentially, driven by Fintech distribution and a marked trend in LATAM toward the banking of millions of people historically excluded from the financial system.

Digital wallets, investment platforms, payment providers, and traditional banks reinvent themselves through digital transformation, including the launch of fully digital spin-offs under their brands, are redefining the competitive landscape. In 2025 and continuing into 2026, several financial innovation models are gaining significant traction, including:  

  • BaaS
  • Open Banking and Open Finance
  • Embedded Finance
  • Tokenization of real assets
  • Crowdfunding and crowdlending as mechanisms for financial inclusion

‍Europe has been a major regulatory driver of these models, while Latin America is advancing at an increasingly rapid pace. Countries such as Mexico, Brazil, Colombia, and recently the Dominican Republic have modernized their regulatory frameworks to promote collective financing. At the same time, virtual assets are gaining relevance, and several countries in the region are analyzing specific regulatory schemes.

The common denominator is clear: digital, scalable, data-driven models with no significant physical assets and exponential growth.

Globally, we are seeing business models grow rapidly, reaching millions of customers across multiple countries at a pace that would have been unthinkable just a few years ago. And this is not limited to the financial sector. Passenger transport, accommodation, and delivery platforms, for example, operate globally with millions of users and share a common characteristic: they do not own the underlying assets, yet they reach massive scale and often possess richer data than the banks themselves. In fact, this is where the concept of embedded finance comes from: the integration of financial products into non-financial platforms so they can offer banking services to their customers.

In this context, a key question arises:  

What happens to the Chief Compliance Officer in this new ecosystem?‍

The new risk environment

Current models generate structural challenges:

  • Faster growth
  • Cross-border operations
  • Financial disintermediation
  • Intensive use of data
  • Collaborative ecosystems (APIs, third parties, BaaS)
  • Digital assets and tokenization

In this context, the CCO must ask themselves:

  • Are we prepared to manage BSA/AML/Sanctions risks in these new models?
  • Do we really understand how these digital businesses work?
  • Are we adequately exploiting advanced technology?
  • Can we identify emerging risks preventively?

The answer to these questions will define the CCO's success in the coming years.

The RBA: theory vs. practice

Globally, with varying degrees of maturity, countries are moving in line with FATF recommendations toward the effective implementation of the RBA.

But what does this mean in practice?

It means properly segmenting risks by considering:

  • Type of customers
  • Products and services
  • Distribution channels
  • Geographic areas
  • Counterparties
  • Reputation
  • Compliance culture
  • Effectiveness of controls

Proper segmentation allows for:

  • Strengthening controls where risk is material
  • Be more flexible where the risk is low
  • Optimize resources
  • Improve operational efficiency

Without proper segmentation, the system becomes inefficient and loses effectiveness.

Key questions every CCO should be able to answer about AML efficiency:

1. How many false positives does my system generate?

How many of these alerts actually require analysis, and how many should not have been generated? A false positive may be due to atypical transactional behavior that allows me to analyze it and conclude that it should not be reported, but in many cases, they are errors in the parameters or definition of the rules that lead to enormous operational inefficiencies.

Excessive false positives:

  • Make teams inefficient
  • Increase costs
  • Reduce focus on real risks

2. Is my customer universe correctly segmented?

If segmentation is poor:

  • We apply EDD where it is not appropriate
  • High-risk customers may not receive the appropriate level of attention
  • We devote time and effort to customers who present a limited risk‍

3. What level of real automation exists in the organization?

Have I identified processes that could be streamlined with RPA, Python, or intelligent automation? Today, operational efficiency is the central axis of organizational transformation processes because it allows us to be more efficient, save on human resource costs, and provide technological support for tasks with low or no added value.

In many cases, the conversation focuses heavily on AI. While there is clearly a growing trend toward its adoption and it is often seen as the more modern solution, we should not lose sight of the base of the pyramid: a significant percentage of processes consist of routine tasks that could easily be automated, allowing people to focus on higher value-added activities.

4. Am I exploiting data from Compliance?

Today, Compliance is no longer exclusively legal and accounting. The most advanced teams include:

  • Mathematicians
  • Actuaries
  • Data scientists
  • Programmers
  • Regulatory specialists

The objective is clear: to detect deviations from the transactional profile and atypical behavior with respect to its cluster.

5. How exposed am I to false negatives?

These are the ones we should be most concerned about: the cases we don't detect and should have analyzed.

All of this leads us to a central topic: strategic and operational efficiency.

Strategy and alignment: the CCO as a business partner

We are increasingly finding organizations where corporate and compliance strategies are misaligned.

The CCO should ask themselves:

  • Do I have a clear understanding of my institution's strategy?
  • Is my risk management framework aligned with it?

Independence does not mean isolation. The modern CCO is no longer an inaccessible figure. They are a strategic partner to management, actively participating in:

  • New product development
  • Risk assessment from the design stage
  • Definition of limits
  • Process optimization

Every compliance area has a strategy. The difference lies in whether it is explicit, consistent, and communicated.

Operational efficiency in the age of AI

Having a strategy is the starting point, and from there, being able to transform internal processes to make them more effective and efficient.

Can false positives be reduced? No, they cannot, they must.

Can processes in compliance areas be automated? Without a doubt, more can be digitized, leaving humans to perform tasks with greater added value.

What additional controls can be put in place? Geolocation gives us key data to mitigate the risks of money laundering and fraud. IP is an essential tool for monitoring where customers connect and avoid the risk of penalties operating in sanctioned jurisdictions; that is why connecting accounts from a VPN should be prohibited.

Can it be more efficient by measuring internal productivity? Without a doubt. With BI tools, it is possible to know in real time how many alerts are pending resolution, how old they are, how many alerts each analyst has, how long it takes to close an alert, and even to rank the best performances.

With AI tools, we can prioritize alerts according to their likelihood of ending up in a report, we can standardize closing conclusions, and we can even analyze a case by researching public information and proposing a conclusion for the analyst, an experienced professional, to evaluate and make a decision.

Technology will not replace humans, but CCOs who embrace change, research, and enhance their programs with tools such as RPA, BI, AI, and blockchain, and know how to exploit their potential will be better prepared for the compliance of the future.

Our vision at Socorro Partners

At Socorro Partners, we combine technical and regulatory knowledge of BSA/AML/OFAC with the expertise of our Management Consulting team in strategy, processes, organizational and digital transformation, and we have a team of programmers who support companies in streamlining processes and systems.

We are a firm with a strong focus on specialization, seeking to add value to each project. We have a professional team with many years of experience, which allows us to provide innovative solutions tailored to each need.

We accompany organizations in:

  • Digital risk assessments
  • Diagnosis and strategic roadmap
  • Capacity analysis
  • Process redesign
  • Alert recalibration
  • Co-creation of automated risk matrices
  • System implementation
  • PMO and change management
  • Specialized training

We are convinced that transformation is a cultural challenge, that technology is now a commodity, and that being at the forefront of these issues is the way to build a more effective and much more efficient future.

Nicolás Franco
CEO, LATAM & Spain
nfranco@socorropartners.com
+1.305.606.7650
Adriano Mucelli
Managing Director
amucelli@socorropartners.com
+1.786.479.3956

Glossary of terms

View all terms →

Abbreviation

Full name

CCO
Chief Compliance Officer
PMO
Program and project management office
RPA
Robotics process automation
BSA
Bank Secrecy Act
AML
Anti-money laundering
OFAC
Office of Foreign Assets Control
FATF
Financial Action Task Force
EDD
Enhanced Due Diligence
AI
Artificial intelligence
API
Application programming interface
IP
Intellectual property
VPN
Virtual Private Network
BaaS
Banking-as-a-Service
LATAM
Latin America
BI
Business intelligence
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