AMLA ¦ Hennie Verbeek-Kusters on the Preventive Power of AML/CFT

AMLA makes the case for measuring AML/CFT by what it prevents

Speaking at the International Anti-Financial Crime Summit in London on 7 October 2026, AMLA Executive Board Member Hennie Verbeek-Kusters set out a view of anti-money laundering and countering the financing of terrorism (AML/CFT) that goes beyond arrests, prosecutions and asset recovery. The framework’s greatest strength, in her account, lies in its preventive effect: raising the cost and risk of abusing the financial system before criminal proceeds are placed, layered or used. For obliged entities, supervisors and financial intelligence units, the message has practical consequences for how effectiveness will be judged once the new EU single rulebook applies.

Supervision, intelligence and risk analysis under one roof

AMLA brings together direct and indirect supervision, support and coordination for financial intelligence units (FIUs), and risk analysis within a single European authority. The reasoning behind this design is that no part of the AML/CFT system works on its own. Supervisors need financial intelligence to decide where to focus, intelligence is only useful with a clear understanding of risk, and risk assessments matter only if they lead to action by supervisors, FIUs, obliged entities, regulators and law enforcement.

When supervisory findings feed into the understanding of risk and the production of financial intelligence, authorities can better anticipate how criminal networks exploit weaknesses in the financial system. FIU cooperation connected to supervision and risk analysis places individual cases in a wider strategic context. The intended result is a shift from reacting to individual incidents toward anticipating threats and designing system-wide interventions, at a European rather than a national level.

Bastian Schwind-Wagner _Follow

"AMLA is signalling that effectiveness will be judged by more than enforcement statistics. Blocked channels, rejected onboarding attempts and disrupted mule networks count as results too, and firms that cannot show them will struggle to prove their controls work.

Fraud is where this becomes concrete. Institutions that still run fraud detection and AML monitoring as separate silos should connect them well before July 2027, because the earliest signs of laundered fraud proceeds usually show up in exactly the payment flows both teams are watching."

10 July 2027 is a milestone, not a finish line

Much of the market is focused on 10 July 2027, when the new AML Regulation becomes applicable. AMLA treats the date as a milestone. From that point on, the system has to prove its value in practice.

Verbeek-Kusters used the image of a marathon. Early milestones create momentum and help measure progress, but endurance, rhythm and discipline decide the outcome. For firms, this bears on implementation planning. Models, policies, regulatory technical standards and cooperation structures are inputs, and effectiveness will be judged by what they produce: better analysis, better prioritisation, a better understanding of risk, better prevention and better interventions.

Enforcement matters, but it is too narrow a yardstick

Financial intelligence can be decisive in criminal cases. It can reveal hidden connections, identify facilitators, expose criminal business models and help law enforcement follow the money in ways that change the course of an investigation. AML/CFT should contribute to arrests, prosecutions, asset recovery and the dismantling of criminal networks.

Measuring success only through those outcomes misses the preventive side of the framework. Well-implemented AML/CFT rules reduce criminal opportunities before harm occurs. They raise barriers, increase transparency and make misuse of the financial system more difficult, more costly and riskier. When a network is disrupted before funds reach their destination, when an institution closes a channel that was about to be abused, or when beneficial ownership transparency exposes misuse and stops further abuse, the framework has done its job, whether or not a prosecution follows.

How prevention has already changed criminal options

Anyone who has worked in the field for some time will recognise the examples. Not long ago, criminal cash could be deposited at a bank counter with little difficulty, and accounts could be opened under fictitious names or stolen identities. Both have become far harder. Buying property with large amounts of cash is more complicated across Europe than ever before. The EU regime for crypto-assets makes the sector harder to misuse for illicit financing, and verification of payee, which checks the name of the intended recipient against the account details, makes certain fraud schemes more difficult.

None of these measures is foolproof. Criminals adapt, move activity across jurisdictions and increasingly use technologies such as artificial intelligence to produce convincing fake identities and documents. The cumulative effect is still that abusing the financial system requires more effort, sophistication and resources than it used to. For money laundering risk management, the displacement effect matters: where one channel closes, typologies shift to the next weakest point.

The new package adds a cash limit and real estate transparency

The new EU AML/CFT package is expected to reinforce this preventive effect. The AML Regulation introduces an EU-wide limit on cash payments, which removes one of the simplest ways of integrating criminal proceeds into the legitimate economy. Article 18 of the Sixth Anti-Money Laundering Directive (AMLD6) requires Member States to establish a single electronic access point that gives national competent authorities, and AMLA for joint analyses, immediate, free and direct access to information on real estate ownership and transactions.

Real estate has long been a preferred vehicle for laundering proceeds of corruption, fraud, drug trafficking and tax crime, partly because ownership and transaction data are scattered across registers and professions. Faster access to consolidated data should support earlier detection and make the sector less attractive for future misuse. Obliged entities active in real estate transactions, including notaries, agents, lenders and fund managers holding property, should expect authorities to compare their reporting more easily against what the data show.

Fraud as the clearest test case

Fraud gets particular attention. It harms citizens, businesses and public finances across Europe on a massive scale, and it is becoming more digital, more cross-border and more complex. It also typically leaves a clear financial footprint. As a predicate offense, fraud generates proceeds that must be received, moved and withdrawn through accounts, payment services and crypto-asset providers, which places obliged entities in a position to see the pattern early.

The AML/CFT framework therefore has potential in deterrence and prevention as well as in investigations. Early identification of mule accounts, unusual inbound payment patterns and rapid onward transfers can help stop losses before victims are harmed further. Realising that potential requires a holistic view of risk, a connection between intelligence and prevention, and coherent interaction between reporting, analysis, supervision and policy. If the system can reduce the number of fraud victims while dismantling the most significant organised fraud networks, prevention and enforcement reinforce each other.

What obliged entities should take from it

The emphasis on prevention has direct implications for compliance functions. Supervisors are likely to ask whether controls actually stop abuse, in addition to whether suspicious transactions were reported after the fact. Fraud and money laundering controls that are run separately, with different data, alert logic and escalation paths, sit uneasily with this approach. Firms should be able to show how transaction monitoring, fraud detection and suspicious transaction reporting inform each other, and how intelligence received from FIUs or public-private partnerships changes controls.

It also makes sense to document preventive outcomes. Exits from high-risk relationships, blocked payment channels, rejected onboarding attempts and closed mule networks rarely appear in enforcement statistics, but they are evidence that a framework is working. Institutions that record and analyse them will be better placed to demonstrate effectiveness when AMLA and national supervisors begin to assess it under the new rulebook.

A long race toward a more resilient system

Detection, investigation and support for enforcement remain part of the job, but the goal AMLA describes is a financial system that is harder to abuse in the first place. Getting there takes ambition, operational focus and stamina. Lasting results in AML/CFT are built over time, and the integrated architecture AMLA is building will be judged by whether criminal abuse of the financial system becomes harder, rarer and less profitable.

Dive deeper

• Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) ¦ Hennie Verbeek-Kusters highlights the importance of prevention in AML/CFT at International Anti-Financial Crime Summit ¦ Link