AMLA/ECB ¦ AMLA and ECB sign Agreement on Cooperation

AMLA/ECB ¦ AMLA and ECB sign Agreement on Cooperation

AMLA and ECB Sign MoU to Strengthen Cooperation on AML/CFT Supervision

The memorandum of understanding signed on 27 June 2025 formalises practical modalities for cooperation and information exchange between the European Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) and the European Central Bank (ECB). The document establishes a structured framework to ensure timely, efficient and proportionate sharing of supervisory information where the mandates of both institutions intersect, in particular for credit institutions that are subject to both prudential supervision under the Single Supervisory Mechanism (SSM) and AML/CFT oversight under AMLA. The MoU is framed as a statement of intent: it does not create legally enforceable rights but sets out procedures, contact arrangements, confidentiality rules and a list of documents to be shared routinely.

Institutional representation and channels of cooperation

Under the agreement, the Chairs of the two bodies may attend each other’s relevant meetings as observers and exchange meeting materials and minutes insofar as confidentiality permits. The MoU foresees regular bilateral exchanges at senior level to align supervisory priorities and encourages direct communication between identified units and responsible persons. It specifies English as the working language for exchanges, requires the use of secure channels, and contemplates joint participation in external communication on matters of shared interest.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"The MoU signed between AMLA and the ECB on 27 June 2025 creates a structured, confidentiality‑protected framework for timely information sharing and coordinated action where AML/CFT and prudential supervision intersect, aimed at improving the detection and management of ML/TF risks while preserving each institution’s legal competences."

Information exchange procedures and data scope

The MoU distinguishes three modes of information exchange: systematic sharing of documents listed in an annex, exchange upon “simple” written request for items referenced in relevant EBA Guidelines, and exchange following formal written requests where greater detail is needed. The annexed list specifies the routine items the ECB will share with AMLA — such as SREP outcomes on business model, operational risk and governance for significant institutions that are also selected obliged entities, on‑site planning and fit-and-proper decisions with AML/CFT assessments — and the items AMLA will share with the ECB, including ML/TF risk assessments, planning of on-site activities, proposals to withdraw authorisations for serious AML/CFT breaches, and whistleblowing reports relevant to prudential supervision.

Confidentiality, permissible use and safeguards

Both Participants commit to preserving confidentiality and limiting use of received information to lawful purposes related to their statutory tasks. The MoU requires compliance with Union law on professional secrecy and sets out procedures for disclosure to third parties, including mandatory notification where a Participant is legally compelled to release information. Information-sharing in emergency situations and coordination on enforcement, administrative measures or supervisory interventions are covered, with a clear emphasis on close coordination where actions such as withdrawal of authorisation, governance changes, or public sanctions may have overlapping effects.

Cooperation beyond information exchange

The agreement encourages knowledge exchange, training, possible staff secondments, and exploration of joint IT or procurement initiatives to support supervision and data flows. It also includes provisions for periodic review every two years, procedures for dispute settlement by amicable means, and clauses on termination with six months’ notice while preserving confidentiality obligations post-termination.

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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Dive deeper
  • AMLA ¦ AMLA and ECB sign agreement on cooperation ¦ Link
  • ECB ¦ ECB and AMLA sign agreement on cooperation ¦ Link
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.