03 July 2025
AMLA/ESAs ¦ Multilateral Memorandum of Understanding on Cooperation and Exchange of Information
New Multilateral Memorandum of Understanding Strengthens AML/CFT Cooperation Between AMLA and the ESAs
The Multilateral Memorandum of Understanding signed on 27 June 2025 formalises a practical cooperation framework between the Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) and the three European Supervisory Authorities (EBA, EIOPA and ESMA). The document sets out principles, channels and safeguards for regular and ad‑hoc exchanges of information, observer participation in boards and committees, joint policy development, and the protection of confidential and personal data. It is an intent‑based agreement that does not create new legal rights or change existing laws, but it creates predictable routines to improve responsiveness where anti‑money laundering and countering terrorist financing concerns overlap with banking, insurance, pensions and securities supervision.
The MMoU emphasises timely, need‑to‑know sharing of information that may affect an institution’s financial soundness, solvency or conduct, and identifies circumstances requiring automatic notice — such as suspicions or elevated risks of ML/TF involving supervised entities, governance or control weaknesses, authorisation or fit‑and‑proper matters, and critical third‑party provider risks under sectoral rules like DORA or MiCA. Practical arrangements include nomination of contact points, mutual invitations for observers at board and committee meetings when topics fall within overlapping mandates, joint chair meetings at least twice a year, and the commitment to consult in advance on policy instruments that may touch the competence of another authority. The MMoU also requires secure channels for exchanges, continued confidentiality and professional secrecy in line with relevant EU rules, and processing of personal data under Regulation (EU) 2018/1725.
Although non‑binding, the MMoU contains operational provisions to speed coordination:
- reasoned responses where a request for information is denied;
- review of cooperation every two years; and
- provisions to ensure termination does not undermine prior obligations or ongoing work.
Publication on the AMLA and ESA websites promotes transparency about the cooperation framework.
Overall, this agreement aims to reduce supervisory fragmentation, close information gaps that can obscure ML/TF risks, and support a more coherent EU response to threats against financial integrity and market stability.