EC ¦ ProtectEU: Agenda to Prevent and Counter Terrorism

ProtectEU Agenda – What it means for financial crime prevention and investigations

A strengthened EU response to terrorism has major implications for financial crime practitioners. The Commission’s ProtectEU Agenda published 26 February 2026 maps out measures across prevention, protection and response that will reshape how money flows linked to terrorism and violent extremism are detected, traced and prosecuted. For anyone working in compliance, FIUs, banks, fintechs, anti-fraud units or law enforcement, the document signals both new responsibilities and new tools – including an explicit roadmap toward an EU-wide financial data retrieval capability and tighter public–private cooperation on emerging payment methods.

Anticipating the financing threat – research, data and foresight

ProtectEU stresses the need for better anticipation of threats and makes research into new technologies a clear priority. The Commission will direct Horizon Europe and Internal Security funding to studies on early detection, AI-driven analytical tools, and emerging terrorist financing methods such as crypto-assets, NFTs and “digital hawala” (p. 3). This means regulators and private-sector compliance teams should expect encouragement – and later requirements – to adopt more sophisticated, research-backed detection technologies. The Commission also plans to support testing and deployment of EU-funded solutions for law enforcement, which could include analytics platforms adaptable for financial investigations.

A practical consequence is that the EU will accelerate the translation of research into operational tools. Financial crime teams should monitor new funding calls and pilots that will likely produce vendor offerings and open-source toolkits intended to detect patterns across hybrid payment channels and decentralised finance. Early engagement with pilot projects and research consortia will offer a first-mover advantage in integrating novel detection capabilities.

A new EU Financial Data Retrieval System – scope and timeline

Perhaps the most consequential financial measure announced is a study launching in early 2026 to identify what is needed to build an EU-wide system for retrieving financial data to track terrorist financing and proceeds of organised crime. The Commission sets an objective for such a system to be established by 2030 and explicitly signals an ambition to cover intra-EU and SEPA transactions, crypto-asset transfers, and online and wire payments.

For practitioners, this announcement highlights two near-term priorities.

1. Expect political and technical workstreams that define data types, legal safeguards, access conditions, and interfaces with FIUs and law enforcement.
2. The timeline suggests progressive interoperability steps: legislative and technical design, piloting, and phased roll-out over several years. Compliance officers should anticipate new legal instruments enabling more direct, expedited retrieval of payment data by competent authorities and plan for upgrades to data retention, logging and legal support procedures to respond to future orders under such a system.

Bastian Schwind-Wagner _Follow

"The ProtectEU Agenda makes clear that financial intelligence and compliance functions are central to preventing and disrupting terrorism-related financing. Institutions should prioritise readiness for tighter EU data access, enhanced FIU cooperation, and targeted controls on crypto and informal transfer mechanisms.

Immediate steps include reviewing transaction monitoring for emerging payment methods and strengthening secure, rapid reporting channels with FIUs and law enforcement. Early engagement in pilots and EU-funded projects will help organisations adapt to the forthcoming EU Financial Data Retrieval System and evolving regulatory expectations."

Evolving typologies – crypto, digital hawala and misuse of online platforms

ProtectEU explicitly recognises the misuse of crypto-assets, NFTs and digital hawala for financing terrorist activity. The Agenda also highlights opportunistic links between terrorism, organised crime and cybercrime, including crime-as-a-service models and underground banking networks. That confirms what many FIUs and analysts have reported: criminal ecosystems increasingly mix traditional financial flows with decentralised or opaque instruments to evade detection.

Operational implications include heightened scrutiny of on- and off-ramps, platforms facilitating peer-to-peer transfers, privacy-preserving services and intermediaries in the Web3 stack. The Commission will support closer cooperation between FIUs, law enforcement, financial institutions and fintechs. For regulated entities this strengthens the case for enhanced due diligence on emerging payment rails, improved transaction monitoring rules for crypto-related activity, and better information sharing with authorities under secure channels.

Tackling Undesirable Foreign Funding (UFF) and protecting EU funds

ProtectEU draws attention to foreign financial influence as a distinct risk vector – termed Undesirable Foreign Funding (UFF) – and calls for better cooperation between FIUs and intelligence services. The Commission also signals stricter protection of EU funds, noting that support for projects that “incite discrimination, hatred or violence” (p. 16) is a ground for exclusion from EU funding and pledging improvements to the anti-fraud architecture.

Practically, organisations receiving EU finance should expect tougher vetting and post-award monitoring. FIUs and investigators will be encouraged to include UFF in national risk assessments and to treat suspicious foreign-state-linked funding with priority. Financial institutions facilitating transfers to or from entities involved in projects with EU funding should be prepared for increased queries and potential reporting obligations tied to fund integrity.

Information sharing, FIU empowerment and public–private partnerships

The Agenda emphasises strengthening cooperation and information exchange between FIUs, law enforcement, financial institutions, fintechs and online service providers. It encourages FIUs to have mandates and capacities to detect UFF and other funding channels. In addition, the Commission will back the Network of counter-terrorism financial investigators and aims to harness contributions from Europol’s public–private partnerships.

For compliance teams this means two operational changes:

1. more structured and perhaps automated channels for sharing indicators of suspicious activity with FIUs and Europol;
2. a reinforced expectation to participate in multi-stakeholder networks, pilot information exchanges, and potentially to accept standardized formats for threat intelligence and financial indicators.

Firms should inventory their reporting procedures and technical capabilities to share relevant metadata securely and rapidly.

Lawful access, electronic evidence and cross‑border co‑operation

ProtectEU links improved law enforcement access to electronic evidence with criminal-financial investigations, underscoring the implementation of the 2025 Roadmap for lawful access and the EU rules on cross-border access to electronic evidence coming into effect in August 2026. These developments aim to streamline preservation and access to service-provider held data and to bolster judicial cooperation through upgraded tools at Eurojust and Europol.

For financial investigators, the practical upshot is improved legal frameworks for securing transaction data, communications and traceroutes from service providers and payment intermediaries across jurisdictions. Compliance and legal teams should prepare for accelerated judicial or administrative requests and ensure that preservation, logging and cooperation workflows comply with both national rules and the evolving EU instruments.

Regulatory and enforcement signals – AML transposition and EU coordination

The Agenda urges Member States to transpose the 6th Anti-Money Laundering Directive by 10 July 2027 and references the forthcoming application of the EU Anti-Money Laundering Regulation and interconnection of bank account registers by 2029. These instruments, combined with strengthened Europol and Eurojust mandates, indicate a future environment of tighter EU-level coordination in detecting and prosecuting terrorism-linked financial crime.

Compliance teams should prioritise readiness for the 2027 transposition deadline and the technical integration tasks that will follow – especially those linked to cross-border account tracing and interoperability. Expect supervisory scrutiny to intensify where gaps remain, and national FIUs to seek greater operational partnerships with private sector counterparts.

Operational tools and capacity building – where funding will flow

ProtectEU commits specific funding lines to protective security, public‑space projects and resilience measures, and describes EUR allocations for prevention and community engagement. On the financial side, the Commission’s support for training and networks indicates funding for capacity building and pilot cooperation mechanisms that can be leveraged by FIUs, LEAs and private-sector partners.

Teams responsible for training, knowledge management and external engagement should track calls and programs that fund technical assistance, shared analytic platforms, and cross-border exercises. Participation offers both practical experience and a channel to influence the operational design of future EU tools.

Key takeaways for practitioners

ProtectEU signals a clear EU strategic direction: integrate financial intelligence into a whole‑of‑government counter‑terrorism posture, prioritise new technologies and data systems, and narrow technical and legal obstacles to rapid cross-border financial investigations.

Near-term actions for practitioners should include:

• reviewing transaction monitoring rules for crypto and non-traditional instruments;
• strengthening reporting channels and legal readiness for expedited data requests;
• engaging with FIUs, Europol and sectoral pilots; and
• preparing for new EU-level retrieval capabilities that will require operational and technical adaptation.

The Agenda will evolve through evaluations and legislation (notably the study and the 2030 target for an EU Financial Data Retrieval System). Financial crime teams that act now to align policies, update technical capabilities and participate in industry‑wide dialogues will be better placed to meet the demands of a more integrated European counter‑terrorism finance architecture.

Dive deeper

• EC ¦ EU Agenda on preventing and countering terrorism and violent extremism ¦ Link