01 July 2026
AMLA ¦ Summary of the 9th Meeting of the General Board in Supervisory Composition
AMLA sets out a more coordinated approach to money laundering risks, sanctions and enforcement
The European Union’s Anti-Money Laundering Authority (AMLA) is moving forward with a broad package of supervisory and regulatory measures covering money laundering, terrorist financing, targeted financial sanctions and enforcement. The work reflects a central challenge for the EU’s new framework: creating consistent standards across sectors and Member States while keeping supervisory demands proportionate to the risks faced by obliged entities.
A significant part of the work concerns the relationship between money laundering and the predicate offences that generate illicit proceeds. Effective supervision cannot focus solely on whether firms have formal anti-money laundering controls. It must also assess whether those controls can identify, understand and disrupt the proceeds of fraud, corruption, sanctions evasion, organised crime, tax-related offences and other underlying criminal conduct.
A structured supervisory framework is taking shape
AMLA is developing its supervisory methodology, cooperation and enforcement frameworks, and a central AML/CFT database. Preparatory work on the database has focused on ensuring that it remains proportionate, efficient and limited to information needed for AMLA’s legal responsibilities.
The emphasis on proportionality is important. Excessive or duplicative reporting can divert resources away from the analysis of suspicious activity, including transactions connected with predicate offences. A more structured data framework could reduce ad hoc information requests and improve the comparability of information received from national supervisors and obliged entities.
The planned approach also reflects the need for better supervisory convergence. Criminal proceeds frequently move across borders, sectors and legal entities. Differences in reporting practices, risk classifications or supervisory expectations can create weaknesses that criminals may exploit. Consistent data and common methodologies are therefore not merely administrative tools – they are part of the EU’s ability to trace and disrupt illicit financial flows.
AMLA is also considering how self-regulatory bodies should contribute to its work. The proposed model would involve ad hoc participation, targeted consultations and structured information-sharing, rather than permanent membership of AMLA internal committees. This could provide sector-specific insight, particularly in non-financial professions exposed to property crime, fraud, corruption and the concealment of beneficial ownership.
At the same time, the distinction between supervisory authorities and self-regulatory bodies must remain clear. Information shared with external bodies will require appropriate confidentiality safeguards, especially where it concerns suspicious transaction reports, ongoing investigations or intelligence linked to predicate offences.
Transition to direct supervision creates legal uncertainty
The General Board approved draft Implementing Technical Standards (ITS) on cooperation between AMLA and financial supervisors in the context of direct supervision. The standards are intended to define how AMLA and national authorities will cooperate as supervisory responsibilities change.
Members raised concerns about cases that remain open when responsibility transfers from a national authority to AMLA. Administrative enforcement proceedings can last for extended periods, and uncertainty over which authority may continue a case could affect both procedural legality and the practical ability to impose sanctions.
This issue has direct relevance to money laundering enforcement. A delayed or interrupted supervisory process may weaken the response to serious control failures, including failures to identify criminal proceeds, investigate high-risk customers or report suspicious transactions. It may also complicate action against institutions that have facilitated financial crime through inadequate controls, even where the underlying predicate offence is being investigated separately.
The proposed approach seeks to minimise disruption by encouraging national authorities to complete proceedings during the transition period. Remaining matters would be managed through bilateral cooperation between AMLA and the relevant national authorities. The European Commission’s Legal Service is expected to assess the final draft following its formal submission.
Non-financial sectors face a difficult risk-assessment test
AMLA endorsed the launch of a public consultation on a methodology for assessing money laundering and terrorist financing risks in the non-financial sector. The methodology is intended as an initial and relatively simple framework because the sector includes entities with very different business models, levels of AML/CFT maturity and supervisory capacity. It also covers newly regulated entities and many small businesses.
The proposed model uses a limited set of indicators and data points adapted to individual sub-sectors. It gives greater weight to inherent risk than to the quality of controls in calculating residual risk. Indicators relating to ownership structures are included, and smaller entities may benefit from a simplified approach.
That focus is significant for predicate-offence risk. Complex or opaque ownership structures can be used to conceal the beneficiaries of fraud, corruption, embezzlement, sanctions evasion or organised crime. In sectors such as real estate, legal and accounting services, gambling and certain high-value goods markets, the risk may arise not only from the movement of funds but also from the acquisition, transfer or conversion of assets derived from crime.
Members nevertheless questioned whether entity-level assessments would be workable across large populations of obliged entities. Concerns included the availability and quality of data, the cost of collection and the capacity of national supervisors to analyse the results. Alternative options included broader use of simplified methodologies, population-based assessments and sampling.
These concerns are not simply matters of administrative convenience. A methodology that demands extensive low-value reporting may reduce the capacity available for higher-risk analysis. Conversely, a methodology that is too broad or too simplified may fail to identify entities exposed to particular predicate offences, such as trade-based fraud, bribery, professional money laundering or the misuse of legal persons.
The consultation is expected to examine implementation costs, feasibility and alternative approaches. The methodology will be refined after feedback and further work within AMLA’s internal structures.
Targeted financial sanctions are being integrated into AML controls
AMLA also outlined its approach to targeted financial sanctions. The EU’s sanctions framework and its AML/CFT framework are legally distinct, but sanctions-related risks increasingly overlap with money laundering controls.
The failure to implement or the deliberate evasion of targeted financial sanctions can involve concealment of beneficial ownership, the use of front companies, indirect ownership arrangements, falsified trade documentation, third-party payments and complex transfers through several jurisdictions. These techniques may also involve proceeds from predicate offences or support broader criminal networks.
AMLA intends to address sanctions-related requirements through existing mandates and a dedicated set of guidelines. The proposed framework will cover risk assessment, customer due diligence and ongoing monitoring. A dedicated task force involving AMLA’s supervisory and private-sector standards structures is expected to lead the work.
Members stressed the need for consistency with guidance issued by other European bodies, particularly the European Banking Authority and the European Central Bank. Conflicting or duplicative requirements could make implementation harder, especially for groups operating across financial and non-financial sectors.
The planned guidance is expected to use a principles-based approach. This should allow firms and supervisors to respond to changing sanctions risks without relying on rigid rules that may quickly become outdated. AMLA also plans to consider how national authorities responsible for sanctions policy and implementation could contribute while preserving confidentiality.
A comprehensive set of guidelines is expected by the second quarter of 2027.
Enforcement convergence remains a priority
The General Board approved draft Regulatory Technical Standards on enforcement for submission to the European Commission. It also considered guidelines on the base amounts used to calculate pecuniary sanctions.
The standards are intended to support greater consistency in enforcement across Member States. Differences in sanctioning practices and levels can produce uneven outcomes and may encourage regulatory arbitrage. Institutions may be drawn towards jurisdictions where failures to prevent money laundering or terrorist financing are less likely to result in meaningful consequences.
The issue is particularly important where weaknesses affect the detection of predicate offences. A failure to identify suspicious activity linked to large-scale fraud or corruption should not receive materially different treatment solely because the institution operates under a different national enforcement culture. Consistent principles can help ensure that penalties reflect the seriousness, duration and consequences of a breach.
AMLA proposed exploring guidance on the final sanction amount in addition to the calculation of a base amount. Most members preferred not to extend the scope at this stage. They supported first implementing the technical standards and base-amount guidance, then assessing their practical impact before considering further harmonisation.
This cautious approach recognises that sanctions remain closely connected to national legal systems and administrative traditions. It also preserves discretion for competent authorities while leaving open the possibility of additional convergence in the future.
Risk methodologies will depend on testing and calibration
AMLA is continuing to test and calibrate risk-assessment methodologies under the AML Regulation and the AML Directive. A common sample has been developed to support consistency between the financial and non-financial sector methodologies.
National competent authorities are expected to remain closely involved in assessing indicators, thresholds and possible methodological changes. Members requested early engagement on the composition of samples, the identification of eligible entities and the treatment of cross-border institutions.
Calibration will be central to the framework’s credibility. Poorly calibrated indicators may classify too many entities as high risk, creating unnecessary supervisory and reporting burdens. Alternatively, thresholds that are too permissive may fail to identify institutions or sectors exposed to significant criminal proceeds.
The quality of the underlying data will also matter. Risk assessments based on incomplete ownership information, inconsistent suspicious transaction reporting or limited information about predicate offences may create a distorted picture of exposure. Cooperation between AMLA and national authorities will therefore be essential, particularly where criminal proceeds move through several sectors or jurisdictions.
The broader direction: better intelligence, clearer responsibilities
The measures under development point towards a more integrated European approach to financial crime. The focus is shifting from isolated compliance requirements towards common methodologies, coordinated supervision, more consistent enforcement and closer links between AML controls and sanctions compliance.
The effectiveness of this approach will depend on execution. Data must be relevant and reliable. Supervisory expectations must distinguish between genuinely high-risk activity and low-value formal reporting. Authorities must be able to manage cases during the transfer of responsibilities. Guidance must also remain consistent across the financial and non-financial sectors.
Most importantly, AML systems must remain connected to the criminal conduct that generates illicit wealth. Money laundering is not an independent threat detached from the underlying offence. It is the process that allows criminals to preserve, move and use the proceeds of fraud, corruption, drug trafficking, human trafficking, environmental crime, sanctions evasion and other serious offences.
AMLA’s forthcoming methodologies, sanctions guidance and enforcement standards will therefore be tested by a practical question: whether they help authorities and obliged entities identify the people, transactions, assets and structures through which criminal proceeds enter and circulate within the European financial system.
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