EBA ¦ Anti-Money Laundering and Countering the Financing of Terrorism Supervision of Banks is Improving

EBA completes six‑year stocktake — meaningful progress on AML/CFT supervision, but gaps remain ahead of AMLA

The European Banking Authority’s final implementation report draws a clear line under a six‑year programme of reviews of national competent authorities’ (NCAs) approaches to anti‑money laundering and countering the financing of terrorism (AML/CFT) supervision of banks. Between 2018 and 2024 EBA teams assessed 40 NCAs across EU/EEA states, fed back findings, and issued targeted recommendations. The October 2025 stocktake summarises what those NCAs have done in response and hands an up‑to‑date picture to the new EU Anti‑Money Laundering Authority (AMLA).

What has improved

Over the review period, NCAs made broadly significant improvements in three interlinked areas: supervisory frameworks, the practical tools supervisors use, and cooperation with domestic and foreign counterparts.

Supervisory frameworks

Where many NCAs initially lacked clearly articulated AML/CFT supervisory strategies and fit‑for‑purpose plans, most have now put such strategies and plans in place. The report finds that a large majority of NCAs have developed supervisory strategies aligned — or on the path to alignment — with EBA guidance on a risk‑based approach. Supervisory plans are now almost universally used to translate strategy into activity, including both on‑site and off‑site work, the use of entity‑level risk assessments to prioritise work, and clearer links between risk assessment and the allocation of supervisory resources.

Supervisory manuals and tools

Supervisory manuals have been created or revised in most jurisdictions to give supervisors more granular guidance on selecting and using supervisory tools, assessing banks’ AML/CFT systems and controls, and sampling/testing approaches to verify effectiveness. NCAs report a more strategic use of supervisory tools — combining off‑site analytics, targeted questionnaires, desk‑based reviews and intrusive on‑site testing where justified — and more systematic follow‑up on remediation measures.

Domestic cooperation

NCAs strengthened formal cooperation arrangements with financial intelligence units (FIUs), tax authorities and, where relevant, other domestic supervisors that share AML/CFT responsibilities. Memoranda of understanding, defined contact points, IT channels and regular meetings are now more widespread, improving information flows and clarifying responsibilities where oversight is shared.

Cross‑border cooperation

Progress on bilateral cooperation with authorities in other EU Member States and third countries has been notable. The establishment and maturing of AML/CFT colleges since 2020 feature as an effective mechanism for exchanging supervisory intelligence and coordinating supervisory action across jurisdictions.

Bastian Schwind-Wagner_Follow "The EBA’s final stocktake shows clear progress across EU/EEA competent authorities in adopting risk‑based AML/CFT supervision, with stronger strategies, improved supervisory manuals and better domestic and cross‑border cooperation. Remaining gaps in resourcing, prudential coordination and bilateral engagement with third countries will be priorities for AMLA as it takes on its supervisory role."

Where important gaps remain

Resource and capability constraints

Staff shortages, budget limits and the need to develop new technical skills (for example for crypto‑asset risks) remain primary obstacles. Several NCAs reported that reforms and remediation were slowed by resource constraints, and some work remains incomplete because reviews or follow‑ups are recent.

Implementation lag in a minority of NCAs

While the majority have addressed EBA recommendations, the report identifies a substantial minority where supervisory strategies, manuals, plans or cooperation mechanisms are only partially implemented or still being developed. In many of these cases the implementation review itself was recent, suggesting remediation is ongoing, but some jurisdictions show limited progress.

Domestic coordination frictions

In Member States with multiple authorities sharing AML/CFT responsibilities, coordination improved but was not uniformly effective. A number of NCAs still need clearer division of tasks, more routine information exchange and formal debriefing practices so that all domestic supervisors receive and act on relevant supervisory intelligence.

Cooperation with prudential supervisors

Cooperation with prudential authorities improved in most cases, but nearly half of NCAs were found to have made limited progress or to be only partially compliant with earlier recommendations. Embedding AML/CFT expertise into the prudential oversight cycle (including SREP) and ensuring targeted training for prudential staff are highlighted as priority operational gaps.

International engagement uneven

AML/CFT colleges work well where established, but bilateral engagement with third‑country counterparts remains uneven. Some NCAs still have limited bilateral engagement despite domestic banking groups’ cross‑border presence; more MoUs and structured information‑sharing arrangements are needed to get a full picture of group‑level ML/TF exposures.

Challenges that slowed remediation

The report recognises structural and contextual impediments that affected NCAs’ ability to implement recommendations swiftly:

1. overlapping international assessments with differing priorities (FATF, Moneyval, IMF, World Bank),
2. the broad institutional and legal reforms triggered by new EU AML/CFT rules, and
3. recent geopolitical developments that created additional supervisory burdens (for example extensive sanctions regimes).

Political priority for AML/CFT and the resulting allocation of resources at national level also influenced progress.

Implications for AMLA and the next phase of supervision

The EBA positions its work as a direct handover to AMLA. The picture it provides should help AMLA prioritise where harmonised standards, methodologies and supervisory convergence are most needed.

Key takeaways for AMLA’s incoming indirect supervisory role include:

• ensuring supervisory strategies clearly translate ML/TF risk assessments into proportional coverage;
• embedding AML/CFT considerations into prudential oversight;
• strengthening manuals and sampling/testing methodologies to make intrusive assessments routine where risks warrant them; and
• driving improvements in international bilateral cooperation, especially with third countries where groups operate.

Practical priorities emerging from the report

NCAs and AMLA would do well to prioritise three practical areas:

• consolidate and resource AML/CFT units so they can follow through on strategic plans;
• institutionalise structured information sharing with FIUs, tax authorities and prudential peers (including clear KPIs and regularised meetings); and
• expand targeted training for prudential supervisors to create an effective two‑way workflow between prudential and AML/CFT functions.

Finally, accelerating bilateral MoUs and using AML/CFT colleges to identify cross‑border vulnerabilities should be elevated as supervisory priorities where cross‑border banking activity is material.

Bottom line

The EBA’s final report documents meaningful, system‑level progress: national authorities are more risk‑focused, supervisory practice is more consistent, and cooperation channels are stronger. Significant work remains in resourcing, coordination, and international outreach — all areas that AMLA’s establishment and the new EU framework are explicitly designed to address. For practitioners and banks, the trajectory is toward more intrusive, better coordinated supervision; for supervisors, the next phase will test whether improved frameworks are matched by durable institutional capacity and consistent cross‑border cooperation.

Dive deeper

• EBA ¦ Anti-money laundering and countering the financing of terrorism supervision of banks is improving, the EBA finds ¦ Link