AMLA ¦ AMLA Roadshow Report 2025

AMLA’s Europe-wide roadshow shows a financial crime system under strain – and in transition

When the European Union’s new Anti-Money Laundering Authority (AMLA) began its work in 2025, it faced a familiar challenge with an unfamiliar scale: how to turn a fresh institutional mandate into practical impact across 27 different national systems. AMLA Chair Bruna Szego answered that challenge by visiting every EU Member State over the course of the year, meeting national supervisors, financial intelligence units, and a wide range of private-sector stakeholders.

The result is the AMLA Roadshow Report, a wide-ranging account of what the authority heard across Europe’s AML/CFT landscape. The report is not a legal text or a policy brochure. It is a snapshot of what practitioners, regulators, and industry groups say is working, what is not, and where the biggest pressures are building. Europe’s anti-money laundering framework is changing, but the change is arriving in a system that is still fragmented, uneven, and under strain.

A shared risk picture, despite national differences

One of the strongest findings in the report is that the core risks look surprisingly similar across the Union, even where national contexts differ. Fraud, cryptoassets, instant payments, cash-intensive activity, real estate, online gambling, sanctions evasion, and the misuse of corporate structures all came up repeatedly.

What stood out was not only the range of risks, but the speed at which some of them are evolving. Technology is changing how criminals move money, hide ownership, impersonate victims, and exploit weak controls. Geopolitical tensions are also reshaping the risk landscape, especially where sanctions circumvention and cross-border exposure are concerned. In several Member States, stakeholders said that these issues have become much more prominent since 2022.

The report shows that financial crime is no longer best understood as a set of isolated typologies. It is increasingly a moving system, where fraud leads to laundering, digital tools speed up abuse, and weak links in one country can be exploited from another.

Bastian Schwind-Wagner _Follow

"AMLA’s Roadshow confirms that Europe’s AML/CFT system is facing the same pressure points across the Union: fragmentation, uneven supervisory maturity, and rapidly changing risks driven by technology and geopolitics. The report makes clear that fraud, cryptoassets, instant payments, and sanctions evasion are central concerns for supervisors and firms alike.

The key message is that the new EU framework can improve consistency, but only if AMLA’s tools are practical, proportionate, and grounded in day-to-day realities. The authority now has an important chance to strengthen cooperation, support convergence, and help build a more effective baseline across Member States."

Fraud is now a major laundering gateway

Fraud emerged as one of the fastest-growing threats discussed during the Roadshow. The report notes that the line between fraud and money laundering is becoming increasingly blurred. Criminals can generate illicit funds through scams, impersonation, or social engineering, and then move those proceeds quickly into laundering channels.

Technology plays a central role here. AI-generated deepfakes, synthetic identities, remote onboarding, and instant payments all shorten the time available to spot suspicious activity. That creates pressure not just on banks and payment firms, but on the wider ecosystem that can be used to enable fraud at source, including telecoms, internet services, and social media platforms.

The report makes an important point here: AMLA does not directly fight fraud as such, but fraud is now so closely tied to laundering that it cannot be ignored. The operational response will need to cut across sectors, not just financial institutions.

Cryptoassets remain a major supervisory challenge

Cryptoassets and crypto-asset service providers (CASPs) were another recurring concern. Across most Member States, stakeholders said the risks are real and still developing. The issue is not only the technology itself, but the practical difficulty of supervising a cross-border market where counterparties can be opaque, transfers are fast, and analytical expertise is unevenly distributed.

The report suggests that while MiCA has moved the EU closer to a formal framework for crypto markets, implementation and supervision still raise difficult questions. Participants pointed to the need for consistent supervisory approaches, better analytical tools, and stronger cooperation across borders.

AMLA’s role here is likely to be closely watched. The report shows a clear expectation that the authority will help harmonise supervision, build shared understanding of crypto-related typologies, and support more effective cooperation between national authorities.

Instant payments are changing the tempo of risk

Instant payments were discussed as both a convenience for legitimate users and a headache for AML/CFT professionals. When funds can move in near real time, 24 hours a day, the traditional model of end-of-day review becomes less effective. Suspicious transactions may be completed before a human analyst can intervene.

This is a major structural issue. The report highlights that faster payments compress the detection window and increase the need for real-time monitoring, quicker information exchange, and stronger preventive controls. It also means that cross-border cooperation becomes more urgent, because a delay in one jurisdiction can quickly become a missed opportunity in another.

Cash and real estate still matter

Even as digital crime grows, the report is careful not to overstate the decline of older laundering methods. Cash remains a major risk factor across many sectors, and real estate continues to offer criminals a way to place and layer illicit funds in a market that can absorb large amounts of capital.

The real estate sector’s opacity, use of nominees, and uneven supervisory maturity were all highlighted. The report also notes that notaries can play a mitigating role where they are involved in transactions, though that is not uniform across the EU.

This part of the report is a reminder that financial crime controls cannot focus only on the newest threats. Some of the oldest routes remain highly effective, especially where supervision is fragmented or awareness is weak.

The non-financial sector still lags behind

A recurring theme throughout the Roadshow was the lower AML/CFT maturity of the non-financial sector. Real estate agents, accountants, lawyers, notaries, high-value goods traders, and other non-financial obliged entities (DNFBPs ) were often described as having limited awareness, limited tools, and limited capacity to carry out robust customer due diligence (CDD).

This is not just a matter of training. The report shows that supervision in the non-financial sector is often dispersed across multiple bodies with different mandates and expertise. That creates uneven expectations, high coordination costs, and a patchwork of enforcement.

The problem is structural. In some sectors, low levels of suspicious transaction reporting are still wrongly read as a sign of low risk, when supervisors and FIUs often see the same pattern as under-detection. That gap in understanding says a lot about the current state of the system.

Technology is both the problem and the answer

If one word runs through the report, it is technology. It appears as a threat driver, a supervision problem, and a possible solution.

On the risk side, technology enables deepfakes, remote onboarding abuse, real-time cross-border transfers, and faster laundering techniques. On the supervision side, many authorities said they lack the data systems, automation, and specialist staff needed to keep pace. FIUs also pointed to interoperability problems and rising report volumes.

But the report is equally clear that technology can help close the gap. Advanced analytics, shared infrastructure, AI-supported tools, and better data quality could all make supervision more effective. AMLA’s early work on a central AML/CFT database and the optimisation of FIU.net points in that direction.

The caveat is important: the authority’s immediate task is to build foundations, not deliver a complete suite of tools overnight. Expectations are high, but the report repeatedly stresses that delivery will take time.

Fragmentation remains the central weakness

The report’s most important structural finding is that Europe’s AML/CFT system is still too fragmented. National differences in supervisory practice, enforcement, intelligence capability, and sectoral maturity create uneven outcomes. Criminals can exploit those differences, especially where cross-border activity is involved.

This fragmentation is most visible in the non-financial sector, but it is not limited to it. Even within the financial sector, different supervisory methods and expectations can create inconsistent burdens for firms operating across several Member States.

That is why the new EU framework matters so much. The report presents the Single Rulebook and AMLA’s coordination role as a direct response to this problem. The goal is not just more rules, but more consistency in how those rules are understood and applied.

What AMLA is being asked to do

The report shows that expectations for AMLA are both broad and specific. Stakeholders want guidance on emerging risks, common supervisory methods, stronger coordination among FIUs, support for public-private partnerships, better information sharing frameworks, and practical capacity building.

At the same time, the report is careful to draw limits. AMLA cannot solve every problem, and it cannot take over responsibilities that remain with national authorities. It also cannot change primary law through technical standards alone. Some of the calls for flexibility would require legislative change, not just better guidance.

Still, the authority is being positioned as a key force for convergence. It is already developing common methodologies, supervisory tools, and coordination mechanisms. Its first draft technical standards, transmitted to the European Commission in December 2025, mark an early step toward a more harmonised framework.

A system in transition, not a finished one

The Roadshow Report does not portray Europe’s AML/CFT system as broken, but it does show a system under pressure. The risks are moving faster. The regulatory structure is changing. Many authorities and firms are starting from very different points. And across much of the non-financial sector, the gap between legal obligation and practical capability remains wide.

What makes the report notable is its tone. It is not alarmist, but it is not complacent either. It suggests that Europe now has the legal architecture, the institutional mandate, and the political direction needed to improve the system. What remains is the harder part: turning that framework into consistent, effective practice across the Union.

For financial crime professionals, that makes the AMLA Roadshow Report more than a summary of meetings. It is a signal of where the next phase of EU AML work is heading – toward harmonisation, shared tools, stronger coordination, and a much sharper focus on how fast-evolving threats are actually managed on the ground.

Dive deeper

• AMLA ¦ AMLA publishes findings of Chair’s 2025 EU-wide Roadshow ¦ Link