AMLA ¦ AMLA and OLAF Sign Working Arrangement on Cooperation

AMLA and OLAF connect FIU intelligence with EU anti-fraud investigations

The EU’s Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) and the European Anti-Fraud Office (OLAF) signed a working arrangement in Frankfurt am Main on 21 October 2026. It is the first formal framework between the new AML authority and the Union’s anti-fraud investigator, and it gives financial intelligence held by national FIUs a defined route to the investigators responsible for fraud against the EU budget.

The legal basis and its limits

The arrangement rests on Article 94 of the AMLA Regulation (EU) 2024/1620, which requires AMLA to establish and maintain a close relationship with OLAF and to conclude a working arrangement for the exchange of operational and strategic information. On OLAF’s side, Article 1(5) of Regulation (EU, Euratom) No 883/2013 permits administrative arrangements of this kind. Two further provisions shape the operational core: Article 41(3) of the AMLA Regulation, which obliges AMLA to report joint analysis results pointing to fraud, corruption or other illegal activity affecting the Union’s financial interests, and Article 32(6) of the AML Directive (EU) 2024/1640, which allows OLAF to be invited into a joint analysis.

The arrangement creates no additional rights or obligations under Union law, leaves both mandates untouched and cannot, on its own, serve as the legal basis for exchanging personal data. Every transfer must find its footing in the parties’ own legal frameworks and in Regulation (EU) 2018/1725 on data protection by EU bodies. Internal investigations by OLAF into AMLA’s Executive Board members and staff are expressly excluded.

Bastian Schwind-Wagner _Follow

"The most consequential line in this arrangement is the one that sends joint analysis results to OLAF without asking the participating FIUs first. Intelligence that national units pool in an AMLA-coordinated analysis can feed an anti-fraud investigation into EU funds, and from there a case for national prosecutors or the EPPO.

For obliged entities, nothing changes on paper, but the audience for a well-drafted suspicious transaction report has grown. Firms banking EU grant recipients, contractors on EU-funded projects or businesses exposed to VAT carousels should make sure their reports name the possible link to public funds explicitly."

A broad scope across fraud, corruption and money laundering

Cooperation covers institutional, strategic and operational matters across fraud, corruption, money laundering, terrorist financing and any other illegal activity affecting the EU’s financial interests. The forms of cooperation range from the exchange of case-related information and investigative findings, spontaneously or on request, to typologies, risk indicators and crime prevention methods, OLAF’s participation in AMLA-coordinated joint analyses, a mechanism to detect early links between the parties’ data holdings, coordination in individual cases where AMLA runs a joint analysis and OLAF an administrative investigation, and training and staff exchanges.

For AML teams, the predicate offense is what matters most here. Fraud involving EU funds – procurement manipulation, subsidy fraud, customs and VAT fraud – generates proceeds that move through the same banking channels FIUs monitor every day. The arrangement lets the two bodies look at those flows together.

Institutional machinery and regular dialogue

Each party designates a single contact point, with the option of ad hoc contacts for specific activities. The Director-General of OLAF and the Chair of AMLA will meet at least once a year, and working-level meetings are to take place regularly to coordinate activities. Before communicating with the media on operations in which both have cooperated, the parties should consult each other, preferably within 48 hours, and may agree on a joint press release.

Strategic intelligence feeds AMLA’s joint analysis priorities

The strategic chapter is fairly concrete. The parties may exchange typologies, trends, risk indicators, lessons learned and crime prevention methods, and they will cooperate on training and awareness-raising involving FIUs. OLAF and AMLA should also exchange information to identify trends, topics and red flags that AMLA should consider when assessing priority areas for joint analyses.

That gives OLAF an indirect voice in where the EU’s FIU coordination effort is directed. If fraud against EU funds features prominently in OLAF’s caseload, it is likely to shape the themes AMLA puts forward to FIUs. The parties may also second liaison officers or experts, under a separate instrument that will settle tasks, numbers and costs.

Joint analysis results reach OLAF without FIU consent

Where the results of a joint analysis coordinated by AMLA give reasonable grounds to suspect fraud, corruption or another illegal activity affecting the Union’s financial interests within OLAF’s competence, AMLA shall transmit those results and any other relevant information to OLAF. Under Article 41(3) of the AMLA Regulation, no consent of the participating FIUs is required for this transmission. The parties may agree on a template for such reporting, and OLAF is to provide feedback on how the information was used and what it produced.

FIU intelligence has traditionally been passed on only with the consent of the FIU that holds it. Once a joint analysis surfaces suspected fraud against EU funds, the results travel to OLAF by operation of law. FIUs contributing to a joint analysis should anticipate that outcome when they decide what to bring to the table.

OLAF’s participation and the hit/no-hit mechanism

For OLAF’s direct participation in a joint analysis, consent is needed. AMLA may invite OLAF only with the consent of all participants, where its involvement is relevant to the analysis and falls within its mandate. OLAF’s contribution is anti-fraud expertise, aimed at the joint operational analysis of money laundering connected to fraud involving EU funds.

The arrangement also sets up cross-matching. AMLA will compare, on a hit/no-hit basis, the data FIUs provide for a joint analysis with information made available by other FIUs and by EU bodies, offices and agencies, including OLAF. In the event of a hit, AMLA informs the participating FIUs and may, with the prior consent of the FIU that provided the data, pass to OLAF the information that triggered the match. AMLA must also grant OLAF access to relevant information in its possession where OLAF needs it to fulfil its mandate, subject to the data protection conditions of the arrangement, and any restrictions on access, use, transmission or erasure bind OLAF and any further recipients.

Consent therefore works in layers: results of a joint analysis flow to OLAF without consent, OLAF’s seat at the table requires the agreement of every participant, and the raw data behind a hit requires the consent of the originating FIU.

Data protection, purpose limitation and secure channels

Personal data may be exchanged only within each party’s legal framework, with the purpose fixed at the latest at the moment of transmission. Data are kept only as long as necessary and proportionate; data that enter an OLAF case file in its case management system follow OLAF’s own retention rules. Incorrect or outdated data must be flagged, corrected or erased, and a data breach at the receiving party must be reported to the sender together with the mitigating measures taken.

Data subjects keep their rights of access, rectification, restriction and erasure, but the transmitting party must be consulted before a final decision is taken, including on any restrictions of those rights. Requests for public access to documents exchanged under the arrangement are referred to the transmitting party for advice. Information may be used only for the purpose for which it was transmitted unless the sender authorises otherwise, and where disclosure could undermine ongoing activities, the parties consult beforehand. Operational information travels only through secure channels, with encryption where appropriate.

What it means for obliged entities

The arrangement imposes no direct obligations on banks, payment institutions or other obliged entities, but it changes where their reports can end up. Suspicious transaction reports filed with a national FIU can now reach an EU-level anti-fraud investigation through two routes: the results of an AMLA-coordinated joint analysis, and a hit against OLAF data. A report concerning a beneficiary of EU grants, a contractor on an EU-funded project or a cross-border VAT carousel may end up informing an OLAF case and, where criminal conduct is established, a referral to national prosecutors or the European Public Prosecutor’s Office.

Precise reporting pays off here. Reports that identify a possible link to public funds, subsidies, public procurement or customs and VAT fraud, and that explain the factual basis for that suspicion, are much easier to cross-match than generic references to unusual transactions. Institutions with clients receiving EU funding should also review whether their risk assessments and transaction monitoring scenarios give sufficient weight to fraud against the EU budget as a predicate offense.

Review every two years

The parties will review implementation within two years of entry into force and every two years thereafter. The first review will show whether the template for reporting joint analysis results has been agreed, how often FIUs consent to OLAF’s participation and how many hits translate into investigations and recoveries. Those figures will show how much FIU intelligence on fraud involving EU funds actually reaches OLAF.

Dive deeper

• AMLA ¦ Press Release: AMLA and OLAF strengthen cooperation in the fight against financial crime ¦ Link