Anti-Money Laundering (AML) Analysts: Know Your Rights on Overtime Pay

Anti-Money Laundering (AML) Analysts play a critical role in keeping the financial system safe. They investigate suspicious transactions, flag potential fraud, and help financial institutions stay compliant with federal regulations. 

But while these analysts are on the front lines of financial crime prevention, many are quietly being denied something much simpler: fair compensation for the hours they work.

At Morgan & Morgan, we’re seeing a growing number of employment law violations involving AML Analysts and other compliance professionals, particularly related to overtime pay. These workers are often misclassified, overworked, and left uncompensated for long hours, despite clear protections under federal and state labor laws.

If you're an AML Analyst or work in a similar role, here's what you need to know about your job, your rights, and what to do if your employer isn't playing fair. If you need free legal advice, contact Morgan & Morgan for a free case evaluation.

What Does an AML Analyst Do?

AML Analysts are compliance professionals who work primarily for banks, credit unions, and other financial institutions. Their main job is to detect and prevent financial crimes, such as:

• Money laundering
• Terrorist financing
• Fraudulent wire transfers
• Structuring (a.k.a. “smurfing”)
• Insider trading
• Cybercrime and identity theft

To accomplish this, AML Analysts review a high volume of transactions flagged by automated systems for potentially suspicious activity. They analyze financial data, prepare written reports for the Compliance or Risk departments, and may file Suspicious Activity Reports (SARs) with the Financial Crimes Enforcement Network (FinCEN).

In many ways, the job is investigative, but it’s also highly repetitive, data-driven, and procedural, which becomes important when evaluating whether an AML Analyst is entitled to overtime pay.

Why Are AML Analysts Working So Much Overtime?

Increased regulatory scrutiny and the rise in financial fraud mean many financial institutions are putting intense pressure on their compliance teams. AML Analysts, in particular, often work long hours, nights, weekends, and holidays to meet internal productivity metrics or respond to audits.

Some of the reasons AML Analysts log overtime include:

• Strict deadlines for reviewing flagged transactions
• Backlogs of alerts or cases
• Regulatory exams (such as OCC, FDIC, or FINRA reviews)
• Inadequate staffing
• Performance metrics that reward speed over work-life balance

Despite this, many AML Analysts are told they're exempt from overtime pay, or they’re simply expected to work extra hours “as part of the job.”

But here’s the truth: Most AML Analysts are non-exempt employees under the Fair Labor Standards Act (FLSA) and are legally entitled to overtime compensation.

The Legal Landscape: AML Analysts & Overtime Law

The Fair Labor Standards Act (FLSA)

The FLSA requires that employees be paid 1.5 times their regular hourly wage for any hours worked beyond 40 in a single workweek, unless they qualify as "exempt" based on their job duties and salary.

To qualify as exempt, an employee must meet certain criteria under one of the following categories:

1. Executive Exemption (management and supervisory duties)
2. Administrative Exemption (work related to business operations requiring independent judgment)
3. Professional Exemption (advanced knowledge in a field of science or learning)
4. Computer Employee Exemption
5. Outside Sales Exemption
    

AML Analysts are often wrongly classified under the administrative exemption, but courts and the Department of Labor have increasingly found this classification doesn’t hold up. Why?

Because the duties of most AML Analysts are:

• Heavily guided by procedures and protocols
• Routine and repetitive in nature
• Not supervisory
• Lacking the degree of discretion or independent judgment required for exemption

In other words, many AML Analysts do important work, but they are not necessarily “exempt” from overtime pay under the FLSA.

Recent Lawsuits Involving AML Analyst Overtime Claims

Several large banks and financial institutions have been hit with lawsuits alleging FLSA violations for failing to pay overtime to their AML staff. In some cases, companies have agreed to settle these claims for millions of dollars.

For instance, HSBC USA Inc. settled an overtime lawsuit in which AML investigators alleged they were wrongly classified as exempt and denied overtime pay.

JPMorgan Chase and Citibank have faced similar litigation over compliance roles including AML, KYC (Know Your Customer), and EDD (Enhanced Due Diligence) staff.

These lawsuits often point out that financial institutions trained AML Analysts to follow strict checklists and escalation protocols, and that employees had little discretion or authority to deviate from established procedures.

Courts tend to side with workers when it's clear their role is more execution-based than decision-making.

How Employers Misclassify AML Analysts

Misclassification can happen in a few different ways:

Job Title Misrepresentation

An employer might use a title like “AML Compliance Officer” or “Senior Risk Analyst” to imply a level of authority that doesn’t exist in practice.

Exaggerating Discretion

Employers may argue that AML Analysts exercise discretion and judgment when, in reality, the job consists mostly of following internal rules and software-generated alerts.

Misusing the Administrative Exemption

This is the most common route. But as we've mentioned, routine investigative work tied to predefined guidelines rarely meets the FLSA’s criteria for exemption.

Are You Entitled to Overtime as an AML Analyst?

You might be eligible for back pay and potential damages if:

• You regularly worked over 40 hours per week
• You were paid a salary and not offered overtime
• Your duties involved reviewing and analyzing alerts based on preset criteria
• You had limited discretion or authority in decision-making
• Your employer claimed you were exempt from overtime, but your actual job responsibilities were more clerical or technical in nature

If this sounds like your situation, you could have a claim under the FLSA or applicable state wage laws.

What Can You Recover in an Overtime Lawsuit?

If you pursue a case for unpaid overtime, you may be entitled to:

• Back pay for unpaid overtime (up to 2–3 years depending on willfulness of the violation)
• Liquidated damages, which often double the amount owed
• Attorney’s fees and court costs
• Reinstatement or protection from retaliation (in some cases)

Many of these cases result in class or collective actions, where a group of similarly affected employees joins the suit, giving it more power and visibility.

What to Do if You Suspect Wage Theft

If you believe your employer is violating wage laws, you can take the following steps:

1. Document Everything

Keep records of your hours worked, communications about overtime expectations, and your job responsibilities.

2. Request a Classification Review

Ask HR or your compliance team how your role is classified and why. This can serve as important evidence later.

3. Consult a Wage and Hour Attorney

Speaking to a lawyer does not obligate you to take action, but it helps you understand your options and protect your rights.

4. File a Complaint (If You Choose)

You may file a complaint with the Department of Labor or file a lawsuit directly with a law firm like Morgan & Morgan.

How Morgan & Morgan Can Help

AML Analysts protect banks, and by extension, the economy, from some of the most dangerous forms of financial crime, but too often, their own rights are being violated behind the scenes.

If you're working long hours in a compliance role without fair compensation, it's time to ask: Who’s protecting you?

At Morgan & Morgan, we fight For the People, not the powerful. 

Morgan & Morgan is America’s largest plaintiffs’ law firm, and we’ve helped thousands of workers recover the wages they’re owed. We have a dedicated team of employment attorneys who specialize in wage and hour cases, including those involving complex financial services roles like AML Analysts.

If you believe you’ve been misclassified or denied overtime, contact us today for a free, confidential case evaluation to learn more about your legal options.