GRECO ¦ Outcome of the 100th Plenary Meeting

GRECO ¦ Outcome of the 100th Plenary Meeting

100th GRECO Plenary Meeting – Key decisions and implications for anti‑corruption and financial crime prevention

The Group of States against Corruption (GRECO) held its centenary plenary in Strasbourg on 3, 4 and 6 June 2025. Chaired by David Meyer, GRECO used the milestone session to review ongoing evaluations, compliance procedures, outreach and institutional partnerships. The meeting reaffirmed GRECO’s role as a central monitoring mechanism for anti‑corruption reform across Council of Europe member states and strengthened ties with international partners, particularly the European Union and OECD. Several practical decisions taken at the plenary carry direct relevance for financial crime prevention, compliance practitioners and policy makers.

Leadership outreach and international cooperation

GRECO’s leadership reported active engagement with international fora and partners, underlining the organisation’s connectivity to broader rule‑of‑law and anti‑corruption agendas. The President’s participation in the OECD Global Anti‑Corruption and Integrity Forum and in parliamentary ethics discussions, and scheduled meetings with the European Commissioner responsible for democracy, justice and rule of law, highlight GRECO’s influence on high‑level policy debates. This continued engagement is important for financial crime stakeholders because it helps align GRECO recommendations and monitoring findings with international standards, harmonising expectations for transparency, asset disclosure, conflict‑of‑interest rules and integrity measures that reduce corruption‑related risk in financial systems.

Evaluation rounds and targeted assessments

The plenary advanced the Sixth Round of evaluations, focused on preventing corruption and promoting integrity at sub‑national levels. Teams were approved for Latvia, the Netherlands and Poland, and the Secretariat reiterated the need for member states to provide timely lists of sub‑national authorities proposed for evaluation. For financial crime practitioners, the Sixth Round’s sub‑national emphasis is significant – many corruption risks and laundering vulnerabilities emerge at local government level through public procurement, licensing, land registers and permit schemes. Strengthening integrity frameworks at regional and municipal levels is therefore an essential step to reduce opportunities for illicit financial flows.

The meeting also recorded the commencement of Sixth Round evaluation visits in Estonia and the Slovak Republic, with further visits planned to Luxembourg and Slovenia. These evaluations will generate new country reports and recommendations that financial investigators, compliance officers and policy advisers should monitor closely for jurisdictional variations in risk and for evolving best practice.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"GRECO’s 100th plenary reinforced the organisation’s central role in monitoring anti‑corruption reforms across Europe and signalled increased coordination with international partners to strengthen integrity frameworks. The focus on sub‑national evaluations and persistent calls for publication of reports underscore where practical risks and transparency gaps remain.

For financial crime professionals, GRECO’s decisions mean renewed scrutiny of local governance, procurement and asset declaration systems, and potential regulatory shifts following high‑level missions and compliance follow‑ups. Staying informed of upcoming Sixth Round reports and compliance updates will be essential for effective risk assessment and cross‑border cooperation."

Ad hoc and compliance procedures with operational consequences

GRECO adopted an ad hoc Rule 34 report on the Slovak Republic and set a deadline for a situation report by 31 December 2026. Such ad hoc procedures are triggered by exceptional concerns and often indicate areas where urgent reforms are expected. For the financial crime community, the outcomes of ad hoc procedures can presage legislative or institutional changes – for example, amendments to prosecutorial structures, enhanced asset recovery mechanisms, or new transparency measures – all of which affect investigative and compliance strategies.

The plenary addressed compliance across previous evaluation rounds. It adopted compliance reports and addenda for a number of member states under Fourth and Fifth Round procedures. Cyprus, Czechia and Romania received Fifth Round compliance reports with deadlines for further progress by the end of 2026, while Denmark, Malta, the Slovak Republic and Spain were found not to be in sufficient compliance and were asked to report back on progress by 30 June 2026. GRECO’s use of Rule 32 revised to invite letters from the Secretary General of the Council of Europe to foreign ministers underlines the political pressure it can apply. From a financial crime perspective, inadequate compliance identified by GRECO often correlates with residual systemic risks, such as weaknesses in senior official asset declarations, conflicts‑of‑interest management, or limited independence of prosecutorial bodies responsible for complex financial investigations.

Publication and transparency expectations

GRECO again emphasised the importance of prompt and consistent publication of evaluation and compliance reports by member states. The Council of Europe Transparency Framework adopted in May 2025 further reinforces the call for openness. GRECO asked specific delegations to authorise publication of outstanding reports from 2023 and 2024. For practitioners, timely publication matters: GRECO reports provide authoritative assessments and actionable recommendations that can inform risk assessments, due diligence frameworks and policy advocacy. When reports are delayed, jurisdictions may retain unexamined deficiencies that impede coordinated responses to cross‑border financial crime.

Capacity building and outreach – engaging universities and civil society

The plenary highlighted GRECO’s education initiative with the Federation for European Education (FEDE), which has reached over 32,000 students since 2019. GRECO also organised a side event on transitioning from the Fifth to Sixth Evaluation Round that engaged numerous civil society organisations. These outreach and capacity‑building efforts have downstream benefits for financial crime prevention by expanding awareness of corruption risks among future professionals, encouraging academic scrutiny and enhancing civil society’s role in monitoring and whistleblowing.

High‑level missions and practical follow‑through

GRECO planned high‑level missions to Türkiye and Poland in 2025 and reported on a high‑level mission to Denmark conducted under Rule 32 revised. Such missions are often followed by targeted recommendations or requests for action at ministerial level. Financial crime investigators and compliance professionals should track the outcomes of these missions because they can signal forthcoming regulatory reform, shifts in prosecutorial priorities or new cross‑border cooperation opportunities.

Implications for financial crime practitioners and policy makers

GRECO’s 100th plenary underlines several practical implications:

  • Continued international alignment: GRECO’s active engagement with the European Commission and OECD suggests a strengthening of normative expectations around integrity and anti‑corruption, which will influence EU and national compliance frameworks that intersect with anti‑money laundering (AML) and countering the financing of terrorism (CFT) obligations.
  • Focus on sub‑national risk: Upcoming Sixth Round findings will likely highlight governance and oversight gaps at local and regional levels – a space where procurement fraud, bribery and concealment of assets can generate significant financial crime risk.
  • Political leverage and compliance pressure: GRECO’s readiness to escalate matters via Rule 32 revised and to publicise non‑compliance creates incentives for swift reform. For compliance officers, this can translate into changes in national enforcement approaches and resources that affect cross‑border investigations and asset recovery.
  • Transparency and data for risk assessment: GRECO’s persistent call for prompt report publication improves access to authoritative country assessments that should be integrated into enhanced due diligence and country risk matrices.

What to watch next

Financial crime stakeholders should monitor the following developments arising from GRECO’s work:

  • the Sixth Round country evaluation reports as they are published;
  • the situation reports due from jurisdictions asked to provide further information by mid‑2026 and end‑2026;
  • the outcomes of high‑level missions and any ministerial letters triggered by Rule 32 revised; and
  • the Secretariat’s continued outreach with civil society and academic partners that may surface new data and case studies relevant to risk assessment.

Conclusion

The 100th GRECO plenary combined symbolic significance with concrete decisions that have material implications for anti‑corruption and financial crime prevention. By prioritising sub‑national integrity, pressing for compliance, and strengthening international and civil society engagement, GRECO is shaping the transparency and accountability landscape across Europe. Practitioners involved in AML, compliance and financial investigations should factor GRECO findings into their strategic assessments, monitor upcoming country reports closely and prepare for the practical effects of anticipated reforms.

The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
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Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.