Edition: computed from the bank pages as of Oct 21, 2026, methodology at /banks/ai-index/methodology
By depth of compliance AI evidence, with breadth across four areas (AML and KYC, model risk, AI governance, fair lending) as the second key, the banks leading in compliance AI are Deutsche Bank, TD, BNY, Customers Bank and Société Générale: Deutsche Bank (3 of 4 areas, 3 in production of 4); TD (3 of 4 areas, 4 in production of 5); BNY (3 of 4 areas, 4 in production of 4); Customers Bank (3 of 4 areas, 3 in production of 5); Société Générale (4 of 4 areas, 5 in production of 5). 139 of the 140 profiled banks have compliance AI on the record; 53 describe AML or KYC AI and 3 cover all four areas.
Data as of Oct 21, 2026 · 140 banks profiled (120 US, 20 non-US) · 139 with evidence on this topic · 86 sources cited below · ranked answer, not a comparison · Which large banks lead in responsible AI? (AI index)
Which banks have AI for compliance on the record, and across how many areas?
The 30 highest of the 139 banks with a compliance use case (tagged aml-kyc, model-risk, governance-general or fair-lending) or a dated AI move on compliance, AML, KYC, sanctions, surveillance, model risk, regulators or audit. Ranked by depth score, then by how many of the four areas the bank covers, then by US AI-index score.
| # | Bank | AI index score | AML, KYC and sanctions AI (stage) | Model risk, governance and fair lending (stage) | Latest compliance AI move | Breadth · stage · depth | Status | Date | Sources |
|---|---|---|---|---|---|---|---|---|---|
| 1 | Deutsche Bank | n/a | Named-entity extraction for sanctions and embargo checks in trade finance (in production) · Agentic Source of Wealth in private-bank KYC (rolling out) | AI risk inside the control framework (in production) · AI & Data Ethics Principles and AI training (in production) | Private-banking CIO: several hundred use cases, a handful of lighthouse projects (Sep 14, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 4 · depth 24 | In production | Oct 5, 2026 | Deutsche Bank Corporate Bank ↗ · Finextra ↗ · Deutsche Bank ↗ |
| 2 | TD | 91.5 | AI models in US AML monitoring and investigations (in production) · ML in transaction monitoring and the new KYC platform (in production) | AI risk management under the model lifecycle (in production) · Agent observability and guardrails (in production) | US bank details AI in AML, engineering and the call centre (Sep 17, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 4 in production of 5 · depth 21 | In production | Sep 22, 2026 | Motley Fool (Yahoo Finance) ↗ · MarketBeat (Yahoo Finance) ↗ · TD Bank Group (SEC filing) ↗ |
| 3 | BNY | 89.6 | AI review of restricted-party screening and communications surveillance (in production) | Anomaly detection in daily calculations (in production) · Community-bank AI training (in production) | INSITE 2026: AI in wealth workflows (Jun 4, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 4 in production of 4 · depth 18 | In production | Jul 28, 2026 | Fortune ↗ · Behavox (Business Wire) ↗ · BNY ↗ |
| 4 | Customers Bank | 75.3 | AI KYC screening and OFAC false-positive clearing (pilot) | Standardised AI risk framework and AI Innovation Lab (in production) · AI charter, acceptable-use policy and use-case scoring (in production) | Q2 2026 call: underwriting, KYC and close-cycle results (Jul 24, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 5 · depth 18 | In production | Jul 24, 2026 | Customers Bancorp (Business Wire via Morningstar) ↗ · Customers Bancorp ↗ · ICBA (Independent Banker) ↗ |
| 5 | Société Générale | n/a | Instant-KYC remote onboarding (in production) · AI document handling in securities-services KYC (in production) | Legal Assistant for contract review (in production) · Active Shell financial-fragility early warning (in production) | Flagship use-case publication: about 700 data and AI use cases (Feb 1, 2025) | 4 of 4 areas (AML and KYC, Model risk, AI governance, Fair lending) · 5 in production of 5 · depth 16 | In production | Mar 13, 2026 | Societe Generale ↗ · Societe Generale Securities Services ↗ · Societe Generale ↗ |
| 6 | BMO | 85.6 | AI alert triage and adverse-media search (in production) · FIS financial-crimes agent (Anthropic) (announced) | Responsible AI framework (in production) · AI risk directive, Responsible AI Forum and model validation (in production) | Named by FIS among the first in development with its Anthropic-built AML agent (May 4, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 4 in production of 5 · depth 16 | In production | Aug 6, 2026 | Yahoo Finance Canada ↗ · Business Wire via FT Markets ↗ · BMO AI Hub ↗ |
| 7 | BMO Financial Group | n/a | AI alert triage and adverse-media search (in production) · FIS Financial Crimes AI Agent (Claude) (announced) | AI risk directive, Responsible AI Forum and model validation (in production) · Board oversight and approved-tools rule (in production) | Agentic decision-intelligence layer described (Jul 27, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 5 · depth 16 | In production | Jul 27, 2026 | Financial Post via Yahoo Finance Canada ↗ · FIS (Business Wire via FT Markets) ↗ · Bank of Montreal (SEC filing) ↗ |
| 8 | ING | n/a | AI-driven KYC and transaction monitoring (in production) · KYC back-office streamlining (rolling out) | AI Risk Committee and Centre of Excellence (in production) · GenAI risk appetite and AI governance framework (in production) | Six banks publish principles for agentic commerce (Sep 22, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 4 · depth 15 | In production | Oct 5, 2026 | ING Groep N.V. (SEC filing) ↗ · Computer Weekly ↗ · Investing.com ↗ |
| 9 | Citi | 94.7 | Faster account opening and onboarding (in production) · Intelligent document processing for onboarding (in production) | AI risk factor and board oversight (in production) · Mandatory AI training and accelerator network (in production) | Q1 2026 call: a four-bucket AI framework (Apr 14, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 4 in production of 4 · depth 13 | In production | Jul 8, 2026 | Reuters ↗ · The Wall Street Journal ↗ · Citigroup ↗ |
| 10 | Northern Trust | 79.7 | AML/KYC document handling and document digitisation (rolling out) | AI Risk Program and model-risk coverage of AI (in production) · Board oversight and AI briefings (in production) | Founding member of OSI's financial-services working group (Jun 3, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 2 in production of 5 · depth 13 | In production | Sep 14, 2026 | Investing.com ↗ · Northern Trust (SEC filings) ↗ · Northern Trust (SEC filings) ↗ |
| 11 | KeyBank | 79.6 | NiCE Actimize X-Sight AI platform for fraud and AML (in production) · Generative-AI anti-money-laundering screening (pilot) | AI risk-factor disclosure (in production) · Enterprise AI governance and inventory (in production) | About 40 generative-AI proofs of concept (Aug 14, 2025) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 5 · depth 13 | In production | Aug 10, 2026 | NiCE Actimize (Business Wire) ↗ · Bank Automation News ↗ · The Wall Street Journal (Deloitte CIO Journal) ↗ |
| 12 | Flagstar | 65.4 | Anti-money-laundering software and customer privacy spend (in production) | Integrated AI governance workflow (in production) · AI strategy committee and tiered model routing (in production) | Robert Martin appointed Head of AI and Engineering (Mar 16, 2026) | 2 of 4 areas (AML and KYC, AI governance) · 4 in production of 4 · depth 13 | In production | Jul 30, 2026 | American Banker ↗ · Flagstar Bank ↗ · American Banker ↗ |
| 13 | Raymond James | 84.4 | AML due-diligence support (in production) | AI Academy for advisors and associates (in production) · AI risk-factor disclosure and walled-garden controls (in production) | Firm describes Carillon Labs and its model governance gate (Aug 1, 2024) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 5 in production of 5 · depth 12 | In production | Jul 22, 2026 | Raymond James ↗ · Raymond James via Canada NewsWire (Yahoo Finance) ↗ · MarketBeat (Yahoo Finance) ↗ |
| 14 | Deutsche Bank (U.S.) | 77.4 | AI in KYC handling (rolling out) · Agentic Source of Wealth checks in private-bank KYC (rolling out) | Agentic-AI risk factor and AI control framework (in production) · Agentic resilience platform for regulatory tabletop exercises (in production) | Agentic Source of Wealth KYC tool live in Singapore and Hong Kong (Sep 23, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 2 in production of 4 · depth 12 | In production | Sep 23, 2026 | Deutsche Bank ↗ · Finextra ↗ · Deutsche Bank AG (SEC filings) ↗ |
| 15 | OceanFirst | 40.3 | Copilot for AML enhanced due diligence (in production) | Automation Transformation Office, AI governance framework and board oversight (in production) · Management committees for AI, risk and cybersecurity (in production) | CIO explains Copilot, Databricks and the data cleanup (Dec 11, 2025) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 4 · depth 12 | In production | Jul 30, 2026 | American Banker ↗ · OceanFirst Financial Corp. (SEC filings) ↗ · OceanFirst Financial Corp. (SEC filings) ↗ |
| 16 | Scotiabank | n/a | Customer-record validation and AML detection on Scotia Intelligence (in production) · Tangerine AML AI pilot (pilot) | Data ethics and AI governance (in production) · AI Risk Management Policy and model risk framework (in production) | Q3 2026 investor deck: AI in action across the bank (Aug 25, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 4 · depth 12 | In production | Aug 25, 2026 | Scotiabank (The Bank of Nova Scotia) ↗ · Financial Post ↗ · Yahoo Finance ↗ |
| 17 | FNB | 59.2 | no AML or KYC use case described | Decisioning, forecasting and regulatory models (in production) · AI and generative-AI risk factor (in production) | Proxy: Board Risk Committee oversees AI governance (Mar 25, 2026) | 2 of 4 areas (Model risk, AI governance) · 3 in production of 5 · depth 12 | In production | Mar 25, 2026 | F.N.B. Corporation ↗ · F.N.B. Corporation (SEC filings) ↗ · earnings call transcript (The Motley Fool) ↗ |
| 18 | Western Alliance | 71.8 | AI triage in financial-crimes compliance (in production) | AI risk-factor disclosure (in production) · Board and CISO oversight of technology and AI risk (in production) | Q2 2026 10-Q repeats the AI regulatory-focus factor (Jul 31, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 4 · depth 11 | In production | Sep 16, 2026 | Western Alliance Bancorporation (SEC filings) ↗ · Western Alliance Bancorporation (SEC filings) ↗ · Business Wire ↗ |
| 19 | Morgan Stanley | 69.8 | Machine-learning document workflows for onboarding (announced) | Compliance task automation (in production) · LeadIQ (in production) | 2025 10-K weaves generative AI through its risk factors (Feb 19, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 4 in production of 5 · depth 11 | In production | Jul 30, 2026 | Google Patents (USPTO) ↗ · American Banker ↗ · The Motley Fool (Yahoo Finance) ↗ |
| 20 | Cathay Bank | 2.6 | AML and sanctions compliance (Wolfsberg questionnaire) (in production) · AML monitoring and sanctions screening tools (NICE Actimize, LexisNexis Bridger) (in production) | Board oversight with AI expertise (in production) · Technology-change risk factor (no AI reference) (in production) | 2026 proxy: director credited with AI insight (Apr 16, 2026) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 4 in production of 5 · depth 11 | In production | Aug 7, 2026 | Cathay Bank ↗ · Cathay General Bancorp (SEC filings) ↗ · Cathay General Bancorp (SEC filings) ↗ |
| 21 | Renasant | 2.4 | no AML or KYC use case described | AI risk-factor disclosure (in production) · Security review for AI-involving products and processes (in production) | no dated compliance AI move | 3 of 4 areas (Model risk, AI governance, Fair lending) · 5 in production of 5 · depth 11 | In production | Mar 18, 2026 | Renasant Corporation (SEC filings) ↗ · Renasant Corporation (SEC filings) ↗ · Renasant Corporation (SEC filings) ↗ |
| 22 | Schwab | 80.7 | no AML or KYC use case described | Schwab Advisor AI in Action (in production) · Advisor Services AI tooling (in production) | 10-K: AI inside model risk management (Feb 25, 2026) | 2 of 4 areas (Model risk, AI governance) · 3 in production of 3 · depth 11 | In production | May 29, 2026 | Charles Schwab ↗ · American Banker ↗ · The Charles Schwab Corporation (SEC filing) ↗ |
| 23 | UBS (US) | 74.8 | no AML or KYC use case described | AI inside the model-risk framework (in production) · AI framework with risk appetite metrics (in production) | Picked for the FCA's AI live tests (Apr 21, 2026) | 2 of 4 areas (Model risk, AI governance) · 2 in production of 4 · depth 11 | In production | Oct 13, 2026 | UBS Group (SEC filings) ↗ · UBS ↗ · Domino Data Lab (PR Newswire) ↗ |
| 24 | First Hawaiian | 47.2 | no AML or KYC use case described | AI programme strategy and governance (in production) · AI risk-factor disclosure (in production) | no dated compliance AI move | 2 of 4 areas (Model risk, AI governance) · 5 in production of 5 · depth 11 | In production | Jul 15, 2026 | First Hawaiian Bank ↗ · First Hawaiian, Inc. (SEC filings) ↗ · First Hawaiian, Inc. (SEC filings) ↗ |
| 25 | Community Bank N.A. | 41.9 | no AML or KYC use case described | Dedicated AI team (in production) · AI and data governance framework and AI risk factor (in production) | FY2024 10-K lists AI in regulatory and technology risk factors (Feb 28, 2025) | 2 of 4 areas (Model risk, AI governance) · 4 in production of 4 · depth 11 | In production | Jul 28, 2026 | Yahoo Finance ↗ · Community Financial System (SEC filings) ↗ · MarketBeat (Yahoo Finance) ↗ |
| 26 | HSBC | n/a | Dynamic Risk Assessment transaction monitoring (Google AML AI) (in production) · Generative and agentic AI for financial-crime risk (announced) | AI Review Committee and hub-and-spoke governance (in production) | Hong Kong regulator questions HSBC over Singapore AI hub (Oct 6, 2026) | 2 of 4 areas (AML and KYC, AI governance) · 2 in production of 3 · depth 11 | In production | Oct 6, 2026 | HSBC Holdings plc ↗ · Google Cloud (PR Newswire) ↗ · HSBC Holdings plc ↗ |
| 27 | JPMorgan | 89.8 | KYC and transaction-screening AI (in production) | Firm-wide AI use-case portfolio (in production) · AI in model risk management and the 10-K risk factor (in production) | Investor Day: 200,000 LLM Suite users, 175 AI use cases in CIB (May 19, 2025) | 3 of 4 areas (AML and KYC, Model risk, AI governance) · 3 in production of 3 · depth 10 | In production | Jul 22, 2026 | JPMorganChase ↗ · The Motley Fool (Yahoo Finance) ↗ · JPMorgan Chase & Co. (SEC filings) ↗ |
| 28 | Banco Santander | n/a | Openbank anti-money-laundering alert models (in production) | Model-risk scope extended to AI systems (in production) · Common evaluation framework for AI products (rolling out) | Santander AI Lab releases the A2K protocol suite (Sep 23, 2026) | 3 of 4 areas (AML and KYC, Model risk, Fair lending) · 2 in production of 4 · depth 10 | In production | Sep 23, 2026 | Banco Santander ↗ · Banco Santander ↗ · Banco Santander ↗ |
| 29 | M&T | 75.3 | no AML or KYC use case described | AI Risk Oversight (second line) (in production) · AI risk-factor disclosure (in production) | no dated compliance AI move | 2 of 4 areas (Model risk, AI governance) · 4 in production of 4 · depth 10 | In production | Sep 2, 2026 | American Banker ↗ · M&T Bank (SEC filings) ↗ · Fast Company ↗ |
| 30 | Old National | 66.0 | no AML or KYC use case described | AI risk-factor disclosure (in production) · AI Center of Excellence: acceptable use and AI inventory (in production) | RBC conference: Ryan on AI as both opportunity and risk (Mar 10, 2026) | 2 of 4 areas (Model risk, AI governance) · 3 in production of 4 · depth 10 | In production | May 19, 2026 | Old National Bancorp (SEC filings) ↗ · Old National Bank ↗ · Old National Bancorp (SEC filings) ↗ |
Each row quotes the bank's page on this site; the bank link opens the full record with every source. “Not disclosed” means the page records nothing on that point. Banks absent from the table have no evidence on this topic on their page. The AI index score is the bank's score out of 100 on the US AI index; non-US groups are outside that index and show n/a.
Which compliance areas does each ranked bank cover?
The best stage each ranked bank records in each of the four areas; "none" means its page describes no use case in that area.
| Bank | AML and KYC | Model risk | AI governance | Fair lending |
|---|---|---|---|---|
| Deutsche Bank | In production | In production | In production | none |
| TD | In production | In production | In production | none |
| BNY | In production | In production | In production | none |
| Customers Bank | Pilot | In production | In production | none |
| Société Générale | In production | In production | In production | In production |
| BMO | In production | In production | In production | none |
| BMO Financial Group | In production | In production | In production | none |
| ING | In production | In production | In production | none |
| Citi | In production | In production | In production | none |
| Northern Trust | Rolling out | In production | In production | none |
| KeyBank | In production | In production | In production | none |
| Flagstar | In production | none | In production | none |
| Raymond James | In production | In production | In production | none |
| Deutsche Bank (U.S.) | Rolling out | In production | In production | none |
| OceanFirst | In production | Rolling out | In production | none |
| Scotiabank | In production | In production | In production | none |
| FNB | none | In production | In production | none |
| Western Alliance | In production | In production | In production | none |
| Morgan Stanley | Announced | In production | In production | none |
| Cathay Bank | In production | In production | In production | none |
| Renasant | none | In production | In production | In production |
| Schwab | none | In production | In production | none |
| UBS (US) | none | In production | In production | none |
| First Hawaiian | none | In production | In production | none |
| Community Bank N.A. | none | In production | In production | none |
| HSBC | In production | none | In production | none |
| JPMorgan | In production | In production | In production | none |
| Banco Santander | In production | In production | none | Announced |
| M&T | none | In production | In production | none |
| Old National | none | In production | In production | none |
How is this ranking computed?
Use cases counted: those tagged aml-kyc, model-risk, governance-general or fair-lending on the bank's page. Moves counted: dated timeline entries that mention compliance, AML, KYC, sanctions, surveillance, model risk, regulators or audit and also state AI (entries that deny AI use, and penalty or enforcement entries, are left out). Depth score = 3 × in-house compliance use cases in production + 2 × in-house ones at other stages + 1 × use cases that are a third-party platform or a filing disclosure (whatever their stage) + 1 per dated compliance AI move + 2 per disclosed compliance AI figure (alerts, screening, false positives). Depth is the first key; breadth (how many of the four areas have at least one use case) is the second and only separates banks with equal depth; the US AI-index score breaks remaining ties, non-US groups last. The stage shown is always the use case's own stage, never inferred from an enforcement order or remediation programme.
Governance use cases here include every governance-general and model-risk entry, not only those naming a responsible-AI structure; the responsible-AI ranking applies that narrower test.
What are the caveats?
Model risk and AI governance entries describe controls over AI as well as AI used for compliance; both are counted because both are what banks disclose under compliance. The AML column is the narrower read of AI doing compliance work.
Fair-lending AI is rarely disclosed (a handful of banks), so few rows cover all four areas. Depth favours banks with long, well-sourced pages; vendor platforms and filing disclosures are down-weighted, but a bank that names its vendor still scores above one that names nothing.
How does this differ from the AI index?
The AI index has no compliance component; this page keeps only AML, KYC, model-risk, governance and fair-lending AI and ranks by depth of evidence, then breadth across those four areas. The AI index and its method are on their own page; the technology leaders and generative AI guides are hand-written cross-bank tables with their own sourcing.
Which bank leads in AI for compliance?
Deutsche Bank: 3 of 4 areas (AML and KYC, Model risk, AI governance), 3 of its 4 compliance use cases in production.
Which banks use AI for anti-money laundering?
53 of the 140 profiled banks describe AML or KYC AI; the highest ranked are Deutsche Bank, TD, BNY, Customers Bank and Société Générale.
How many banks cover all four compliance areas?
3: Société Générale, City National and Dime.
How many banks have compliance AI on the record?
139 of the 140; 133 describe at least one compliance use case in production.
How is this different from the responsible AI ranking?
The responsible-AI ranking counts named governance structures, AI-risk officers and governance moves; this page counts AI used for and around compliance (AML, KYC, model risk, governance, fair lending) and ranks by depth of evidence, then breadth.
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