Real estate remains one of the most exposed sectors for money laundering because it combines scale, stability, and opacity. Property markets can absorb large sums without immediately drawing attention, and they offer a credible route for placing illicit funds, layering transactions, and integrating criminal proceeds into the legitimate economy. A property can become a store of value, a source of rental income, or a vehicle for capital gains, all while masking the origin of the money used to acquire it.

July 30 marks World Day Against Trafficking in Persons, a day established by the United Nations to raise awareness of human trafficking and strengthen global action against it. While trafficking is often discussed as a human rights abuse, it is also one of the most serious forms of financial crime.

The European Union has adopted its 21st package of restrictive measures against Russia, marking one of the most expansive sanctions steps taken since the full-scale invasion of Ukraine began. The new measures are aimed squarely at the financial channels, revenue sources and logistics networks that help sustain Russia’s war economy. For financial crime professionals, the package is notable not only for its scale, but for how clearly it reflects the EU’s focus on sanctions evasion typologies, including banking intermediation, crypto-asset misuse, shadow fleet activity, dual-use procurement and third-country facilitation.

South-East Asia is not dealing with separate criminal markets that happen to overlap from time to time. The latest UNODC Transnational Organized Crime Threat Assessment (TOCTA), together with recent enforcement material, points to a single connected criminal ecosystem built around drugs, cyber fraud, illegal gambling, trafficking in persons, online child sexual exploitation (OCSE), illicit trade, firearms, waste crime, and money laundering. These crimes share the same people, the same infrastructure, and often the same payment channels.

Luxembourg has now given the financial intelligence unit (FIU), the Cellule de Renseignement Financier (CRF), a formal legal basis to share fraud-related signals with selected professionals in the financial sector. The new law of 22 July 2026 inserts article 74-4bis into the law on judicial organisation and creates article 5-1 in the anti-money laundering law. Together, these provisions establish a structured channel for sharing account-level fraud intelligence where the risk is serious enough to justify intervention.

The 2025 picture of financial intelligence in Germany shows a system under pressure, but also a system that is maturing. The central message is not simply that more suspicious activity was reported. It is that the nature of the workload is changing. As reporting volumes rise, the analytical response is becoming more selective, more data-driven, and more focused on the threats that matter most for money laundering, fraud, and terrorism financing.

Decentralised finance (DeFi) has moved far beyond a niche experiment. By 2026, total value locked in DeFi had risen sharply, and the sector has become increasingly attractive not only to retail users and developers, but also to institutional investors, virtual asset service providers (VASPs), and other regulated firms. That broader participation matters. The more DeFi becomes connected to mainstream finance, the more it can transmit money laundering, terrorist financing, proliferation financing, fraud, and cyber risk into the wider system.

Luxembourg’s draft law No. 8722 marks a significant shift in the country’s approach to financial crime prevention. The proposal amends both the law on judicial organisation and the AML/CFT law to give the Cellule de renseignement financier, or CRF, a clear legal basis to share selected fraud-related information with regulated financial professionals.

The Netherlands continues to stand out in Europe for the high level of trust in its judiciary. Public confidence in the independence of courts and judges is exceptionally strong, and businesses share that view. That matters in financial crime prevention because effective enforcement depends not only on laws and tools, but also on institutions that are seen as fair, stable, and insulated from political pressure.

Luxembourg continues to stand out for the strength of its institutions, the high level of trust in its courts, and a generally solid anti-corruption environment. For financial crime prevention, that matters. A country with strong judicial independence, active oversight bodies, and a relatively low perceived corruption level gives investigators, regulators, and compliance teams a firmer base to work from.

France’s courts continue to enjoy an average level of public confidence, but the more relevant signal for financial crime risk is the strain on judicial independence around politically sensitive cases. Attacks on magistrates, including personal threats, have become more visible, and the response has required stronger police protection in some instances. That matters because financial crime enforcement depends on judges and prosecutors who can act without intimidation, especially when cases involve powerful political or business interests.

Germany continues to combine a high level of judicial independence with an effective anti-corruption enforcement system. That matters for financial crime because strong courts, capable prosecutors, and specialised investigators are the backbone of any system that can detect, pursue, and punish bribery, fraud, and related offences. Public trust in the judiciary is high, and businesses also rate judicial independence positively. For financial crime compliance teams, that is a meaningful indicator: disputes, investigations, and enforcement actions are more likely to be handled in a structured and predictable environment.

Belgium’s corruption risk profile remains mixed. The country still ranks relatively well in international perceptions, but the surface-level comfort that comes with a modest corruption score hides structural weaknesses that matter for financial crime enforcement. Investigations continue, yet several core safeguards that should prevent misconduct, detect hidden influence, and support prosecutions remain incomplete or unevenly applied. The result is a system that can respond to individual cases, but still struggles to build consistent prevention and deterrence.

The idea of the gatekeeper is not new, but its meaning is still far from settled. In financial crime compliance, the term is often used as shorthand for lawyers, accountants, trust and corporate service providers (TCSPs), and real estate agents. These are the types of professionals that global standards first singled out more than two decades ago, when the push was to bring higher consistency to sectors that had not always been regulated in the same way across borders.

Corruption is often treated as a problem of bribery, embezzlement, or weak ethics. That view is too narrow for cases where corrupt conduct is used to shape policy, bend oversight, and create lasting dependence in another state or institution. In those situations, corruption is not just a private crime. It becomes a tool of power.

Luxembourg has updated its anti-money laundering and counter-terrorist financing framework with a law adopted on 16 July 2026 and published on 23 July 2026. The reform adjusts the legal basis of the Comité de prévention du blanchiment et du financement du terrorisme, adds new rules on risk assessment, and formalizes the collection and transmission of AML/CFT statistics. The overall direction is clear: strengthen the national control architecture, align it more closely with EU requirements, and improve the quality of information available to authorities.

Anti-money laundering and countering the financing of terrorism has moved far beyond a box-ticking exercise for banks and supervisors. The latest policy direction puts financial integrity at the center of macroeconomic stability, financial sector resilience, and cross-border spillover analysis. That shift matters because money laundering, predicate offences, terrorism financing, and related illicit financial flows are not isolated criminal risks. They can weaken fiscal capacity, distort credit allocation, damage trust in institutions, and disrupt access to the international financial system.

The FATF’s seventh targeted update on virtual assets and virtual asset service providers shows that jurisdictions have continued to move forward on Recommendation 15, but the pace of progress still falls short of what is needed to address real-world abuse. More countries have carried out risk assessments, more have defined how they intend to regulate the sector, and more have passed Travel Rule legislation. Yet the report makes clear that implementation often stops at the legal drafting stage. Turning rules into effective supervision, enforcement, and disruption of illicit activity remains the core problem.

The Authority for Anti-Money Laundering and Countering the Financing of Terrorism, or AMLA, used its first official annual report to show how far it moved in 2025 – from a legal concept to a functioning European authority with staff, governance, premises, and an initial supervisory and intelligence agenda.

Non-bank payment service providers have become central to modern payments. They offer faster, cheaper and more accessible ways to send money, pay merchants, issue cards and operate digital wallets. Their growth has expanded choice for consumers and businesses, but it has also created difficult financial crime risk management questions for the financial institutions that provide them with accounts, payment access and settlement services.

Whistleblowing is one of the most effective tools for detecting financial crime, regulatory breaches and misconduct that can damage investors, customers, markets and public trust. In financial services, a well-functioning reporting framework does more than surface wrongdoing. It helps expose fraud, corruption, mis-selling, data misuse, discrimination, conflicts of interest and failures in governance before they become larger crises.

Europol’s European Union Terrorism Situation and Trend Report 2026 shows a paradox that matters for financial crime professionals: the number of reported terrorist attacks in the EU fell in 2025, but the threat did not ease. Member States reported 45 attacks, down from 58 in 2024, yet arrests rose to 486, the highest level in the three-year comparison covered by the report. The picture is not one of decline, but of pressure shifting across ideologies, methods and online spaces.

Financial crime rarely starts with a single dramatic act. More often, it grows from repeated governance failures that slowly weaken judgment, oversight, and accountability. A board may begin with good intentions, strong policies, and formal procedures, yet still fail when independence is compromised, power becomes concentrated, and ethical warnings are ignored.

Real estate has long been considered a higher-risk area for money laundering. Property transactions often involve large sums, multiple participants, and several legal and financial steps, which can make it easier to obscure the origin of funds or the person ultimately in control.

Payment behavior has changed quickly in recent years, and financial crime has adapted with it. The FIU Germany paper on alternative payment methods and new technologies brings together a range of digital services and assets that may be relevant for money laundering risk assessments. Its aim is to help obliged entities identify potentially suspicious activity and assess it in context.

The Deutsche Bundesbank’s June 2026 FAQ on financial sanctions offers a useful snapshot of how EU sanctions are working in practice, especially in relation to Russia and Belarus. The document is not legislation, but it reflects the Bundesbank’s legal view and operational approach to enforcement. Financial sanctions are not a narrow screening exercise. They shape deposits, securities, crypto services, banknotes, central bank reserves, and cross-border payments in a far more detailed way than many institutions still assume.

The FATF’s July 2026 report on information sharing to combat illicit finance makes one point very clear: in a world of instant payments, digital channels, cross-border movement, and increasingly sophisticated criminal networks, slow and fragmented communication is no longer good enough. Authorities and private sector institutions need faster, better connected ways to identify and disrupt money laundering, terrorist financing, proliferation financing, fraud, and related predicate offences.

The European Union’s new Anti-Money Laundering Authority, AMLA, is moving from design to practice. The hearing with its Chair, Bruna Szego, comes at a critical moment. The authority must show that it can do more than publish rules and coordinate institutions. It must prove that it can identify the right entities for direct supervision, support meaningful cooperation between national authorities, and make the new EU framework work in day-to-day financial crime prevention.

Real estate is one of the most attractive assets for criminals, corrupt actors, sanctioned persons, and tax evaders. It is valuable, durable, and often easy to hold through layers of companies, trusts, nominees, and other legal arrangements. That is why transparency in real estate ownership is not just a property-law issue.

Politically Exposed Persons, or PEPs, sit at the center of a major financial crime challenge. Because they hold or have held prominent public functions, they can be exposed to a higher risk of bribery, embezzlement, abuse of office, money laundering, and illicit financial flows. When these risks are not properly identified and managed, the consequences reach far beyond individual cases. They can weaken public trust, distort markets, undermine democratic institutions, and damage the rule of law.

The EU anti-money laundering package adopted in 2024 has brought professional football clubs and football agents into the European anti-money laundering framework. This is a major change for the sector. From 10 July 2029, certain professional football clubs and agents will be subject to AML obligations as obliged entities. The new rules are part of a broader move away from fragmented national approaches toward a more unified EU system.

The end of the MiCAR transitional period on 1 July 2026 marks a turning point for the EU crypto-asset market. From that date, firms can no longer continue providing crypto-asset services in the EU unless they are authorised as MiCAR-compliant crypto-asset service providers, or CASPs.

June 26 marks the International Day Against Drug Abuse and Illicit Trafficking, a date that highlights the human cost of drug use and the criminal networks that profit from it. While the public focus is often on health, law enforcement, and social harm, there is another side that deserves equal attention: the financial crime behind the trade. Drug trafficking is not only a criminal market built on violence and exploitation, it is also a money-making system that depends on laundering, concealment, and access to legitimate financial channels.

On 25 June 2026, the Luxembourg financial supervisor, the CSSF, issued Circular 26/914 to alert a broad range of regulated firms that the EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism, AMLA, is collecting data to identify obliged entities that may fall within its direct supervision perimeter.

Europol’s latest assessment of the European Union’s most threatening criminal networks (MTCNs) shows a criminal landscape that has changed in composition but not in danger. The networks identified in 2024 have not simply disappeared. Some were dismantled, others were weakened, and many have been replaced by new actors. Yet the threat remains intense because organised crime has not become smaller. It has become more adaptive.

Corruption rarely moves in a straight line. It is usually hidden behind shell companies, nominee owners, layered transfers, cross-border payments and a trail of transactions designed to look ordinary. That is why financial intelligence units, or FIUs, matter so much. They sit at the centre of anti-money laundering systems, receiving suspicious transaction reports, analysing patterns, and passing on intelligence that can expose the financial footprint of corruption.

GRECO’s 26th General Activity Report makes one point very clear: corruption prevention is still not where it needs to be in Europe and the United States. The Council of Europe’s anti-corruption monitor found some progress in 2025, but also a pattern that matters directly for financial crime professionals: reforms are moving more slowly at the top of government than in law enforcement, and too many safeguards remain incomplete.

The Wolfsberg Group’s latest guidance on the risk-based approach (RBA) sets out a simple but important message: financial institutions should design financial crime risk management programmes around the risks they actually face, not around a generic template. A one-size-fits-all model is not risk-based, and it can leave institutions spending time and money on controls that add little value while under-investing in the areas that matter most.

The sixth and final FATF Plenary under the Mexican Presidency closed in Paris on 19 June 2026 with a wide package of decisions aimed at strengthening the global response to money laundering, terrorist financing, proliferation financing, and related financial crime. Delegates from more than 200 jurisdictions and observer organisations met from 17 to 19 June to address a fast-changing threat landscape shaped by digitalisation, cross-border payment flows, emerging technologies, and increasingly sophisticated criminal networks.

The European Commission’s 2026 evaluation of Directive (EU) 2018/1673 shows that the EU’s criminal law response to money laundering has become more consistent and more effective across much of the bloc. The Directive, adopted in 2018 and applicable to 25 Member States (Ireland and Denmark are not bound by it), was designed to harmonise core money laundering offences, widen the scope of criminal liability, and improve cooperation between national authorities. According to the report, it has largely achieved those aims.

The Luxembourg Financial Sector Supervisory Commission, the CSSF, has addressed growing concerns from individuals and legal entities about difficulties in opening bank accounts in Luxembourg. According to the communiqué, some credit institutions have explained these difficulties by pointing to demanding legal requirements on anti-money laundering and counter-terrorist financing, as well as their understanding of the CSSF’s expectations regarding ML/FT risk exposure.

The French financial markets authority, the AMF, has published a synthesis of its inspections and follow-up actions in the area of anti-money laundering and counter-terrorist financing, covering cases closed between 1 January 2022 and 31 December 2025. Many firms still have AML/CFT frameworks that exist on paper but do not operate effectively in practice.

In 2026, the most important terrorism risks in the United States are not necessarily the ones that rely on large organizations or complex external support. They are the ones that can turn grievances into action using easy-to-access weapons, online radicalization, small-cell coordination, and highly visible targets. The threat is therefore less about mass membership and more about intent, opportunity, and the ability to exploit weak points in public-facing security.

In 2026, the most dangerous terrorist groups in Africa are not necessarily the ones with the largest formal structures. They are the ones that can adapt under pressure, preserve revenue, exploit weak state control, and connect violence to financial and logistical networks.

In 2026, the most dangerous terrorist groups in the Middle East are not necessarily the ones with the largest formal structures. They are the ones that can adapt, preserve revenue, exploit weak state control, and connect violence to financial and logistical networks.

What financial crime teams need to know

The European Union’s 2024 anti-money laundering package marks one of the most significant changes to the bloc’s financial crime framework in years. After long negotiations between EU institutions, the package is now moving from political agreement to practical implementation. For banks, crypto firms, real estate professionals, corporate service providers, supervisors and Financial Intelligence Units, the next phase will be defined by how these rules are applied in practice across Member States.

Internal investigations are changing fast. More data, more tools, and more AI-powered capabilities are giving companies new ways to detect wrongdoing, test suspicions, and secure evidence. At the same time, these options create a harder question: what can be done, what may be done, and what should be done?

LuxCMA’s June 2026 guidance note on the identification of the beneficial owner(s) of orphan securitisation vehicles (OSVs) brings greater clarity to a long-standing problem in Luxembourg market practice: who should be reported as the beneficial owner of an orphan securitisation vehicle, or OSV, for RBE purposes?

Sanctions risk has become a core financial crime issue for firms of every size. It is no longer enough to focus only on asset freezes or basic screening. Effective sanctions systems and controls need to cover the full lifecycle of customer, product, jurisdictional and transaction risk, from governance and risk assessment through to escalation, freezing, licensing and breach reporting.

The Commission de Surveillance du Secteur Financier (CSSF) has placed fresh attention on one of the most sensitive areas in financial reporting: revenue recognition. Its 2025 thematic inspection, published in May 2026, shows that fraud risks in this area are still not being assessed with enough depth by auditors, even though revenue remains one of the most exposed lines in the financial statements.

Foreign bribery cases should not be handled as isolated national matters. The OECD’s 2026 paper on sanctioning foreign bribery through multijurisdictional resolutions (MJRs) shows a clear shift toward co-ordinated enforcement, where several authorities work together to investigate and resolve the same underlying misconduct. This approach is now central to the response to large transnational corruption schemes, especially when corporate conduct touches multiple countries, bank accounts, subsidiaries, and public contracts.

IOSCO’s new Supervisory Toolkit for AI Use in Capital Markets marks an important shift in how regulators are expected to oversee artificial intelligence in financial markets. Rather than treating AI as a distant innovation topic, the report frames it as an active supervisory issue with direct implications for investor protection, market integrity, and financial stability.

The Financial Action Task Force, or FATF, remains one of the most influential bodies in the global fight against money laundering, terrorist financing, and proliferation financing. Its standards shape national laws, regulatory expectations, supervisory priorities, and the day-to-day work of financial institutions and other obliged entities around the world.

The European Commission has clarified a question that has practical relevance for the market in e-money tokens, or EMTs, under MiCAR. The issue was whether electronic money institutions (EMIs) and credit institutions issuing EMTs must comply with the customer due diligence (CDD) obligations in the EU anti-money laundering framework, and whether holders of EMTs should be treated as customers of the issuer for AML purposes.

Luxembourg is moving to strengthen its judicial system with a new law designed to add capacity at the Court of Appeal and the Public Prosecutor’s Office. The bill, documented under parliamentary file 8704, amends the law on judicial organisation to create an additional criminal chamber at the Court of Appeal and to add five magistrate posts overall. For a financial crime audience, the measure matters because delayed appellate proceedings can weaken the practical impact of enforcement, lengthen uncertainty for defendants and victims alike, and slow the final resolution of serious economic and criminal matters.

Sanctions lose their intended pressure when actors successfully bypass restrictions. Circumvention reduces the political and economic leverage that sanctions are meant to exert, allowing high-influence individuals, companies, and state-linked actors to continue accessing resources and markets. Coordinated improvements in data interoperability, legal harmonisation, oversight of professional intermediaries, and enforcement capacity can substantially reduce opportunities for evasion and restore sanctions’ effectiveness.

The new goAML Indicators handbook offers a structured, pragmatic step forward for improving the quality and usefulness of Suspicious Activity Reports (SARs) and Suspicious Transaction Reports (STRs). By grouping factual elements of suspicion into clearly defined categories and selectable indicators, the handbook helps reporting entities provide the Financial Intelligence Unit (FIU) with more precise, consistent and actionable information. That in turn speeds prioritization, reduces follow‑up queries, and strengthens the FIU’s ability to detect typologies and emerging risks. The approach is voluntary but strongly encouraged – it is most valuable when reporting entities choose indicators that accurately reflect the factual elements described in their narratives.

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.

This Foreign Affairs Council session signaled a sharper EU posture across several high-risk files, from Ukraine and the Western Balkans to the Middle East and Syria. The discussion was shaped by one recurring theme: the EU is increasingly linking diplomacy, security policy, sanctions, and accountability tools in a single framework.

The draft law examined by the Conseil d’État and amended by the Chamber of Deputies aims to update Luxembourg’s 2004 law on anti–money laundering (AML) and counter‑terrorist financing (CTF). Its stated objectives are to reinforce the coherence and resilience of the national AML/CTF framework, to align domestic rules with European requirements, and to ensure compliance with obligations within prescribed deadlines. Key elements introduced include a clearer statutory role for the existing prevention committee, a national coordinator function, mandatory national risk evaluations and sectoral reviews, and the compilation and transmission of AML statistics to European bodies.

Understanding the scope and immediate impact of the asset freeze in Council Regulation (EU) No 269/2014 is the essential first step for any compliance team facing potential exposure. The Regulation imposes an asset freeze and a prohibition on making funds or economic resources available to natural and legal persons listed in Annex I. Although the measures target listed persons directly, the reach of the restrictions extends beyond named entities: non-listed companies that are owned or controlled by a listed person are presumptively caught, and funds or services that would, directly or indirectly, benefit a listed person must be blocked. Compliance teams must therefore shift quickly from a checklist mentality to a fact-driven investigation of ownership, control and benefit pathways to identify assets and relationships that fall within the freeze.

Luxembourg authorities have announced a new phase of enforcement aimed at ensuring compliance with the country’s rules on beneficial ownership transparency. In a joint press release dated 4 May 2026, the public prosecutors of Luxembourg and Diekirch confirmed that systematic checks will soon be carried out across the country in relation to the Registre des bénéficiaires effectifs, commonly known as the RBE.

The Internet Organised Crime Threat Assessment (IOCTA) 2026 portrays a cybercrime ecosystem that is both faster and more elusive than in previous years. Criminals are shortening the time between reconnaissance and exploitation while automating many stages of the criminal workflow. End-to-end encrypted (E2EE) apps, layered anonymisation (VPN‑chaining, Tor, residential proxies), self‑deployed hosting and fragmented dark web markets create pervasive investigation blind spots. At the same time, readily available AI tools lower the skills needed to craft convincing social engineering, to generate malicious code variants, or to produce synthetic child sexual abuse material (CSAM). The combined effect is a widening “velocity gap” where law enforcement struggles to obtain timely data, trace transactions and preserve evidence before criminals move on.

The European Union has adopted its 20th package of sanctions against Russia, marking a significant escalation in measures aimed at constraining the funding and logistical capacity that sustain the war in Ukraine. This package broadens the reach of sanctions across energy, finance, trade, and media, while introducing enforcement tools designed to prevent and punish circumvention. For practitioners in financial crime compliance, investigations, and sanctions risk management, the package delivers new obligations, fresh exposures via third‑country actors, and expanded enforcement levers that will require immediate attention.

A Luxembourg draft law, Proposition de loi 8661, aims to close a gap in the country’s legal toolbox by creating a path to dissolve certain holding companies that continue to hold stakes in businesses under criminal investigation or already convicted of serious illegal conduct. The proposal is framed as a response to a structural problem in the Luxembourg market: many SOPARFIs are pure participation vehicles with no real operating activity in the country, which makes traditional enforcement difficult even when the foreign companies they own are linked to serious wrongdoing.

Luxembourg’s draft bill No. 8447 is a clear attempt to respond to one of the most damaging financial crime cases to hit the country’s nonprofit sector in recent years. The text was introduced after the Caritas affair revealed how vulnerable associations and foundations can be to large-scale diversion of funds. According to the explanatory note, the goal is to strengthen financial governance in organizations that collect public donations or receive public funding, and to restore confidence in a sector that depends heavily on trust.

In 2017, the European Union adopted a far‑reaching regulation designed to weaken the financial lifelines of armed groups operating in conflict‑affected and high‑risk areas. The regulation targets tin, tantalum, tungsten and gold – minerals and metals whose extraction and trade have long been linked to human rights abuses, corruption, and the financing of violence. By imposing binding supply chain due diligence obligations on EU importers, the EU has moved responsible sourcing from a voluntary commitment into a legal requirement with direct relevance for financial crime prevention.

The FATF’s fifth-round mutual evaluations mark a clear shift in emphasis from checking whether laws and rules exist to assessing how effectively those measures operate in practice. For AML professionals, business leaders and regulated entities, this means preparation must go beyond technical compliance to demonstrate genuine, measurable outcomes. Greylisting remains a key business risk – it can damage reputation, reduce investment and strain correspondent banking relationships – and the new round of evaluations increases scrutiny on how jurisdictions and the private sector manage and mitigate that risk.

Corporate corruption, fraud and related financial crime are not just compliance problems; they are failures of guardianship. When a limited liability company was first conceived under modern law it was treated as a legal person in need of trusteeship. Directors, and especially the chair, occupy that guardianship role. Their duties of good faith, care, skill and diligence are the primary legal and ethical bulwark against looting, bribery and money laundering.

Over the past two decades, anti-money laundering policy has moved from a niche law enforcement tool to a central pillar of financial integrity and economic governance. While FATF standards have driven broad legal convergence, real-world effectiveness depends as much on institutional design, supervision and enforcement practices as on formal rules. This article draws on a comparative briefing of five major jurisdictions – the European Union, the United States, the United Kingdom, Japan and Singapore – to show how different architectures generate distinct strengths, gaps and trade-offs. The main message is straightforward: legal alignment alone is not enough; supervisory capacity, information quality and credible enforcement determine whether AML rules actually reduce illicit finance and protect market confidence.

On 8 April 2026 the EU adopted a Directive that replaces and significantly expands earlier instruments (Council Framework Decision 2003/568/JHA and the 1997 Convention) and amends Directive (EU) 2017/1371. The new instrument sets common minimum definitions of a wide range of corruption offences, prescribes minimum penalties for natural and legal persons, requires Member States to adopt prevention strategies and anti‑corruption bodies, strengthens investigative and asset recovery tools, and tightens rules on jurisdiction, limitation periods and corporate liability. For anyone working in financial crime compliance, investigations, asset recovery or public procurement, the Directive makes several practical and legal changes that alter risk profiles, investigative options and cross‑border cooperation across the EU.

Financial institutions and other obliged entities face ongoing tension between the need to report suspicious activity promptly and the obligation to ensure reports are complete and useful. Recent practitioner guidance clarifies key concepts that shape how compliance teams should assess, document and transmit suspicious activity reports. This article translates those practical points into everyday compliance actions, focusing on how to balance immediacy and completeness, how internal research should be handled, what to include in reports so analysts can work with them, and how to manage communications with customers and peer institutions without breaching prohibitions on tipping-off.

April 4 – International Day for Mine Awareness and Assistance in Mine Action

April 4 International Day for Mine Awareness and Assistance in Mine Action is widely known as a humanitarian observance. It focuses on the devastating impact of landmines and explosive remnants of war on civilians, long after conflicts officially end. Less discussed, but equally important, is how mine action intersects with financial crime, illicit finance, and economic instability.

Context and scope – why BFPO matters now

Corruption imposes a heavy cost on the global economy, estimated at roughly 6% of world GDP according to UN sources. Cross-border corruption, and in particular the bribery of foreign public officials (BFPO), is a core feature of that burden. Since 2021 Luxembourg has been a party to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and domestic authorities are increasingly focused on detecting schemes where commercial actors secure regulatory or commercial advantages abroad through improper payments. The Luxembourg Financial Intelligence Unit’s (Cellule de Renseignement Financier, CRF) short briefing provides a compact reference for reporting entities that want to spot, investigate and report BFPO risks.

At its 102nd plenary in Strasbourg (23–27 March 2026) GRECO underlined continuity in governance and a clear focus on institutional effectiveness. President David Meyer opened the meeting by thanking delegations for their active engagement in the mutual evaluation process and emphasised that this session was the first plenary to examine evaluation reports from the 6th Evaluation Round – a milestone for the monitoring cycle. The President reiterated procedural expectations: delegations are appointed on a permanent basis, only designated representatives should attend plenaries, and any change to a delegation must be promptly notified to the Secretariat to keep lists and mailing arrangements accurate.

Luxembourg has enacted the law of 27 March 2026 transposing the EU’s DAC8 changes into national law – formally bringing providers of crypto-asset services into the automatic and mandatory exchange of tax-relevant information regime. The law applies from 1 January 2026 and imposes new registration, reporting, and due diligence obligations on “declaring” crypto‑asset service providers (CASPs) and other operators that carry out reportable crypto transactions on behalf of users who are tax residents in jurisdictions subject to reporting. The statute amends several existing Luxembourg laws on administrative cooperation, the Common Reporting Standard (CRS), country‑by‑country reporting (CbCR), cross‑border arrangements, and platform operators to integrate crypto reporting into the international automatic exchange network. For teams working on financial crime risks and tax compliance, the law materially changes the information flows, supervisory responsibilities and enforcement powers that intersect with anti‑money laundering and sanctions controls.

On 26 March 2026 the German Federal Ministry for Digital Affairs and State Modernisation published a detailed draft law to implement the amended eIDAS framework introducing the European Digital Identity Wallet (EUDI Wallet). The draft – titled Digitale Identitätengesetz (DIdG) – translates EU obligations into national rules and sets out how Germany will provide at least one EUDI Wallet, how authorities and private actors interact with the Wallet ecosystem, and how identity, attribute and signature services will be governed. For professionals focused on financial crime, anti‑money laundering (AML) and sanctions compliance, the DIdG matters because it reshapes identity proofing, electronic attribute issuance, cross‑border authentication, and the technical and administrative channels through which transactional and identity risks will surface.

Why well‑designed, timely and ethical messaging is a core tool to prevent fraud, protect victims and strengthen cross‑sector responses

Organized fraud has become a sophisticated, transnational threat that exploits emotion, trust and system gaps to extract money and personal data. The United Nations Office on Drugs and Crime (UNODC) Handbook on Effective Communication Strategies for the Prevention of Organized Fraud (Vienna, 2026) reframes communication as a strategic prevention instrument – one that must be behaviourally informed, inclusive, trauma‑sensitive and integrated into the systems people use when they are most vulnerable.

The European Parliament has adopted a far-reaching directive that establishes a harmonised criminal law framework to prevent and combat corruption across the European Union. Agreed provisionally with the Council in December 2025, the new rules aim to close long-standing legal gaps that have weakened enforcement, especially in cross-border cases. The vote passed by a wide margin, with 581 members in favour, reflecting strong political backing for a more unified response to corruption.

Corruption and fraud are no peripheral problems. They reduce foreign direct investment, raise the cost of doingbusiness, distort public policies, and siphon scarce public resources away from essential services. Faced with tighter publicbudgets and higher demand for services, governments that cannot protect public funds or show the results of their work riskweaker public trust and poorer economic outcomes. The 2026 Anti‑Corruption and Integrity Outlook finds that, despitestronger laws and more strategies in many countries, the central challenge is implementation: governments often have ruleson paper but are not translating them into practice.

March 24 – International Day for the Right to the Truth concerning Gross Human Rights Violations and for the Dignity of Victims

March 24 marks the International Day for the Right to the Truth concerning Gross Human Rights Violations and for the Dignity of Victims. The date commemorates Archbishop Óscar Romero, assassinated in 1980 after speaking out against repression and abuses in El Salvador. Beyond remembrance, the day affirms a principle that is central not only to human rights, but also to financial crime prevention: victims and societies have the right to know what happened, who was responsible, and how abuses were enabled.

The Commission de Surveillance du Secteur Financier (CSSF) has drawn attention to the Financial Action Task Force’s (FATF) “Comprehensive Update on Terrorist Financing Risks” (the Report) and reinforced its relevance for regulated entities. The Report synthesises evidence from mutual evaluations, national risk assessments, questionnaires and stakeholder contributions across more than 190 jurisdictions. It finds that terrorist financing (TF) remains adaptive, context-dependent and increasingly hybrid in technique: traditional cash and informal value transfer systems persist, while digital channels, virtual assets (VAs) and online fundraising are growing. The FATF emphasises that TF actors tailor methods to local economic, geographic, political and enforcement conditions, creating varied risk footprints that require proportionate, evidence-based responses from supervised institutions.

In 2025 Luxembourg’s financial crime division continued its dual approach of strategic preparation and operational enforcement to meet the recommendations issued by the Financial Action Task Force (FATF) and to implement the new AML6 package. At the regulatory level, preparatory work focused on three core instruments of the AML6 package: Regulation (EU) 2024/1620 establishing the EU anti‑money laundering authority, Directive (EU) 2024/1640 setting national mechanisms to prevent misuse of the financial system, and Regulation (EU) 2024/1624 addressing prevention of AML/CFT risks. Those developments have driven policy design, cross‑agency engagement and sectoral impact assessments within the Administration for the year.

Luxembourg’s draft law No. 8722 proposes a targeted change to the country’s anti-money laundering framework by giving the Cellule de Renseignement Financier, or CRF, a clearer legal basis to share fraud-related information with selected obliged entities. The goal is to stop fraud earlier, before suspicious accounts can be reused to steal from more victims or to move illicit proceeds through the financial system.

The integrity of the EU’s external borders is central to Schengen and to internal security, yet technology and investment alone cannot guarantee effective control when institutional integrity is weak. Border corruption is adaptive: as surveillance, controls, and digital systems improve, corrupt networks shift tactics toward points of least resistance – personnel with discretionary power, procurement and maintenance chains, and manual data handling practices. The FALCON project shows that despite robust EU procurement rules and major digital programmes, gaps in scope, uneven national application, and fragile oversight leave persistent vulnerabilities that undermine anti-corruption objectives.

The shift from opportunistic scams to industrialized, AI-enabled fraud has made financial fraud one of the most urgent cross-border criminal threats today. Since 2024, fraud volume and sophistication have surged: INTERPOL data show a 54 percent global rise in fraud-related Notices and Diffusions between 2024 and 2025, with more than 1,500 transnational cases supported and USD 1.1 billion in lost assets tracked. Estimates place annual global losses in the hundreds of billions of dollars, and victims frequently suffer long-term emotional harm that suppresses reporting and obstructs law enforcement response. This article summarises the updated patterns, harms, regional dynamics and priority responses highlighted in INTERPOL’s Global Financial Fraud Threat Assessment, Second Edition (March 2026).

Article 5b(2) of Regulation (EU) No 833/2014, as amended by Regulation (EU) 2025/2033, imposes targeted prohibitions on a narrow set of payment-related activities when provided to Russian nationals, natural persons residing in Russia and legal persons, entities or bodies established in Russia. The measure covers three distinct categories: crypto-asset services, the issuing of payment instruments together with the acquiring of payment transactions and provision of payment initiation services, and the issuing of electronic money. Each category is defined by the relevant EU directives: PSD2 for payment instruments, acquiring and payment initiation; and the EMD2 definition of electronic money. These prohibitions are service-specific – they do not amount to a blanket ban on all forms of banking or payments activity vis‑à‑vis persons in scope.

Conflict zones generate more than humanitarian crises – they create fertile ground for illicit financial flows that sustain violence, enrich corrupt networks, and enable the procurement of weapons and dual‑use technologies. The MONEYVAL December 2025 typologies report on money laundering, terrorist financing and proliferation financing linked to proceeds obtained from conflicts lays out the mechanisms used to extract, conceal and move those proceeds, the emerging global trends, and gaps in national risk frameworks that leave jurisdictions exposed. This article summarises the report’s key messages, illustrates the most consequential typologies, and highlights the practical policy steps needed to limit the financial lifelines of modern conflicts.

Corporations today operate in a far more complex environment than a decade ago. Rapid technological change, expanded sustainability reporting requirements, geopolitical instability, and greater public expectations mean that anti‑corruption work can no longer be just a compliance checkbox. The updated United Nations guide An Anti‑Corruption Ethics and Compliance Programme for Business reframes corporate anti‑corruption systems within the UN Global Compact’s transformational governance approach: integrity becomes a strategic capability that protects value, builds trust and supports long‑term resilience.

Offshore virtual asset service providers (oVASPs) present a growing and complex challenge for anti-money laundering, counter-terrorist financing and counter-proliferation financing regimes worldwide. The FATF’s March 2026 targeted report on oVASPs explains how these entities – VASPs created or located in one jurisdiction that actively provide services into other jurisdictions – can exploit regulatory gaps, frustrate supervision and enable significant illicit-finance activity. This article synthesises the report’s key findings, examines typical abuse patterns, and sets out practical steps that public and private sector actors can take to reduce the risks posed by oVASPs.

The Office des signalements (Office) began full operations in September 2023 after transposition of the EU Whistleblower Directive into Luxembourg law (Law of 16 May 2023). Its 2024 activity report – the second since creation and the first covering a full year of operations – provides a practical snapshot of how Luxembourg’s institutional architecture for whistleblowing is functioning, how signalements (reports) are being routed and handled, and what this means for the detection and mitigation of financial crime risks such as money laundering, fraud, tax abuse and market misconduct.

On 3 March 2026 Luxembourg adopted a law implementing Directive (EU) 2024/927 that amends national rules governing UCITS and alternative investment fund managers (AIFMs). While many changes address liquidity management, delegation and reporting, several provisions have direct or indirect implications for anti‑money laundering and countering the financing of terrorism (AML/CFT), tax transparency and supervisory cooperation. Fund managers, depositaries and service providers operating in Luxembourg must assess how these amendments tighten due diligence expectations, expand reporting channels and change the legal character of certain custody arrangements – all measures that affect the fight against financial crime.

March 5 – International Day for Disarmament and Non-Proliferation Awareness

March 5 – International Day for Disarmament and Non-Proliferation Awareness is often discussed in diplomatic or military terms. Yet its relevance to financial crime prevention is just as strong. Weapons proliferation does not happen in isolation. It relies on complex financial networks, shell companies, trade intermediaries, and cross-border payments that can be exploited when controls are weak. For financial institutions, regulators, and compliance professionals, this day is a reminder that global security risks are deeply linked to financial systems.

Stablecoins have moved from a niche virtual asset product to core market infrastructure. Their appeal is obvious: price stability, fast settlement, broad interoperability and deep liquidity. Those same qualities also make them highly attractive to criminals. By mid-2025, more than 250 stablecoins were in circulation, with total market capitalisation above USD 300 billion and daily trading volumes exceeding Bitcoin. The market is dominated by fiat-backed, centrally governed tokens, especially USD-referenced stablecoins, which are widely used across multiple blockchains and increasingly integrated with the traditional financial system.

The European Public Prosecutor’s Office (EPPO) closed 2025 with 3 602 active investigations and an estimated total damage to public finances exceeding €67.27 billion. Those headline figures are a clear indicator that fraud affecting the EU’s financial interests has reached an industrial scale. Revenue fraud – VAT and customs – alone accounts for roughly €45.01 billion of the damage under investigation, while non‑procurement expenditure fraud remains the single largest category of active cases by number. Equally striking is the EPPO’s workload growth: the Office opened 2 030 investigations in 2025, almost 35% more than in 2024, driven largely by improved cooperation with national authorities and a deliberate focus on organised criminal groups that treat EU funding as a source of mass profits.

The Financial Action Task Force Learning and Development Forum held in London on 25–26 February 2026 brought together more than 100 practitioners from supervisors, financial intelligence units, law enforcement, policy makers, and major international banks to tackle a central problem in the fight against financial crime: turning the risk-based approach from principle into effective practice. The meeting underscored that the next phase of global anti–money laundering and counter–terrorist financing (AML/CFT) work must shift emphasis from compliance checkboxes toward demonstrable effectiveness – allocating resources and supervisory attention to the highest risks to better protect communities and reduce victimisation.

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.

The escalating scale and sophistication of cyber‑enabled fraud pose a systemic threat to financial integrity and public trust. The FATF’s February 2026 paper highlights how rapid digitalisation, including instant payments, virtual assets and AI‑enabled social engineering, has expanded opportunities for fraudsters to generate and launder large volumes of illicit proceeds. Fraud is now recognised as a major money‑laundering risk by 90% of assessed jurisdictions, with losses reaching into the tens of billions annually in some countries and victimisation rates impacting sizable shares of adult populations. The speed and cross‑border nature of modern fraud schemes challenge traditional detection, investigation and asset‑recovery approaches, especially where criminals exploit jurisdictional gaps and convert proceeds into virtual assets or route them through nominee accounts and money mule networks.

The Financial Action Task Force (FATF) plenary in February 2026 issued a fresh set of statements that again reshuffle the priorities for compliance teams, risk officers and financial intelligence units worldwide. The FATF reaffirmed longstanding concerns about jurisdictions whose anti–money laundering and counter–terrorist finance (AML/CFT) frameworks contain strategic deficiencies, called for targeted counter‑measures where appropriate, and requested heightened vigilance and reporting from institutions interacting with listed jurisdictions. The Luxembourg Direction de l’enregistrement, des domaines et de la TVA circulated these outcomes and reminded domestic operators to apply reinforced due diligence and reporting measures.

The Financial Action Task Force’s 2024–2025 Annual Report sets out a year of significant operational progress and strategic change across the global anti–money laundering and counter–terrorist financing (AML/CFT) architecture. Under the Mexican Presidency, the FATF pushed forward revisions to core Standards, completed a fresh round of mutual evaluations of nearly 200 jurisdictions, and ramped up guidance and capacity building on priority threats such as payment transparency, virtual assets, terrorist financing, proliferation financing and online child sexual exploitation. The report stresses collaboration – across FATF members, FATF–Style Regional Bodies, observers, the private sector, civil society and international partners – as essential to making the international financial system less hospitable for criminals and terrorists.

On 17 February 2026 the Council of the European Union approved updated conclusions on the revised EU list of non‑cooperative jurisdictions for tax purposes. The document reiterates the EU’s sustained focus on tax good governance – transparency, fair taxation and measures to prevent tax fraud, evasion and avoidance – and sets out the updated list of jurisdictions deemed non‑cooperative together with the state of play on cooperation from jurisdictions that have committed to reforms. The conclusions also endorse the Code of Conduct Group’s report and annex the EU list and a table of commitments and follow‑up items.

The Financial Action Task Force (FATF) concluded its fifth Plenary under the Mexican Presidency in Mexico City on 13 February 2026, delivering a suite of decisions aimed at tightening global defenses against money laundering, terrorist financing and proliferation financing. Delegates from the FATF’s Global Network of more than 200 jurisdictions and observers met for three days of discussions that balanced country assessments, technological risk responses and strategic planning for the next biennium.

February 12 – International Day for the Prevention of Violent Extremism that Leads to Terrorism

The International Day for the Prevention of Violent Extremism that Leads to Terrorism, observed on 12 February, is often linked to security policy, social cohesion, and counter-radicalisation strategies. For financial crime professionals, its importance lies in a more practical reality. Violent extremism requires funding, and financial systems are one of the most effective points where early intervention can take place.

The Ordre des Avocats du Barreau de Luxembourg published its 2024–2025 AML/CFT annual report in February 2026, documenting legislative changes, supervisory activity, enforcement outcomes and capacity‑building measures affecting lawyers as a supervised profession. The period saw important legal amendments at national level and continuing preparatory work for major European reforms that will reshape anti‑money laundering architecture and obligations for non‑financial professionals.

Practice of Using Virtual Assets and VASPs in Money Laundering, Terrorist Financing and Sanctions Evasion – Key Lessons for Financial Crime Practitioners

MONEYVAL’s December 2025 typologies report confirms that virtual assets (VAs) and virtual asset service providers (VASPs) are now firmly embedded in the AML/CFT and sanctions landscape – but regulatory progress has not eliminated operational gaps. The report documents real advances in licensing, supervision, international cooperation and public–private engagement across MONEYVAL jurisdictions, while also underscoring persistent weaknesses in enforcement, data collection, Travel Rule implementation and the handling of privacy-enhancing technologies. This article synthesises the report’s findings and highlights practical implications for compliance officers, investigators and supervisors.

Global Corruption Perceptions Index 2025: Why the World’s Integrity Deficit Is a Financial‑Crime Threat

The 2025 Corruption Perceptions Index (CPI) from Transparency International (TI) delivers a stark message: the global average score has fallen to 42 out of 100 for the first time in more than a decade, and 122 of 182 countries score below 50. For financial‑crime practitioners, policymakers and compliance officers, this decline matters because corruption and weak governance amplify opportunities for bribery, embezzlement, illicit enrichment, money laundering and transnational asset flight. The CPI shows not only where public‑sector corruption is perceived to be worst, but also where the institutional conditions that enable large‑scale financial crime – politicised judiciaries, restricted civic space, opaque political finance, and poorly overseen public procurement – are most pronounced.

The EU’s new anti‑money laundering and countering the financing of terrorism (AML/CFT) framework introduces a single, harmonised rulebook designed to close gaps created by fragmented national regimes. From 10 July 2027 (and 10 July 2029 for professional football clubs and agents), firms and professions across the non‑financial sector will face consistent obligations to know their customers, assess and monitor risk, and report suspicions. The Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) will play a central role in setting common rules, coordinating supervision and enabling cross‑border financial intelligence sharing.

AMLA’s SPD 2026–2028: building a unified, data‑driven EU response to financial crime

AMLA sets out how it will move from start‑up to full operational capacity over 2026–2028. The Authority’s first Single Programming Document (SPD) makes clear that the next three years will be focused on completing essential regulatory work, standing up both supervisory and FIU functions, and creating the data and IT backbone to make an EU‑level AML/CFT system operational and evidence‑driven.

Luxembourg’s 26 January 2026 conference for specialised professionals of the financial sector, convened by the CSSF and the Financial Intelligence Unit (CRF), made two things plain: the supervisory and intelligence authorities have sharpened their view of money laundering (ML) and terrorist financing (TF) risks linked to trust and company service providers (TCSPs), and they expect firms to translate those insights into tangible, risk‑based controls. The latest sub‑sector risk assessment (SSRA) on specialised professionals providing corporate services sits between the national risk assessment (NRA) and firm‑level risk assessments to produce workable guidance for supervisors and industry alike. Practitioners should strengthen documentation, tailor TF analysis separately from ML, and ensure screening, transaction monitoring and suspicious reporting are timely and relevant.

Luxembourg Business Registers (LBR), under the supervision of the Ministry of Justice, has presented a phased reform to strengthen monitoring, verification and compliance of data in the Trade and Companies Register (RCS) and the Register of Beneficial Owners (RBE). The plan, announced at a press conference on 28 January 2026, is designed to make the registers more accurate, complete and timely so they can be relied upon by public authorities, financial institutions and other economic actors for risk assessment, compliance checks and decision-making.

The Registration Duties, Estates and VAT Authority (AED) published a January 2026 newsletter focused on the AML/CFT supervision of Reserved Alternative Investment Funds (RAIFs) and Alternative Investment Funds (AIFs). The newsletter highlights important quantitative and qualitative failings observed in the 2024 reporting cycle and reiterates the legal duty of these vehicles and their managers to cooperate fully with Luxembourg authorities. The findings point to recurring operational weaknesses that increase regulatory risk for funds and their service providers and warrant immediate remedial action.

The Anti-Money Laundering Authority (AMLA) is set to launch a data collection exercise in March to test and calibrate the risk assessment models it will use to inform the selection of up to 40 financial institutions for direct supervision beginning in 2028. This preparatory phase is intended both to support the 2027 selection process and to promote consistent assessment of money laundering risks by supervisors across the EU.

On January 26, 2026 the Directorate of Registration, Domains and VAT of the Grand Duchy of Luxembourg issued Circular No. 792 quater, updating and clarifying the obligations of professionals under the anti–money laundering and counter‑terrorist financing (AML/CTF) framework. The circular reiterates that professionals supervised by the AED must identify and verify their clients – both natural persons and legal entities or arrangements – using reliable, independent sources and proportionate, risk‑based measures. This article explains the practical implications for compliance teams, highlights key operational changes, and suggests steps firms should take now to align procedures with the circular.

January 24 – International Day of Education

Education significantly reduces financial crime by lowering victimisation, improving reporting quality and equipping professionals with role-specific AML/CFT/CPF and technical skills, making prevention a strategic complement to enforcement. For compliance officers and MLROs, investing in risk-aligned, measurable and recurring training delivers practical reductions in losses, higher quality SARs and stronger institutional resilience.

The EU’s Article 5n of Council Regulation 833/2014 imposes a wide-ranging prohibition on providing certain professional and business services to the Government of Russia and to legal persons, entities or bodies established in Russia. Since its entry into force and subsequent amendments, the measure has expanded beyond classic embargo tools to target services that underpin corporate activity and technological development, including accounting, auditing, tax consultancy, business and management consulting, public relations, IT consultancy and an array of technical, engineering and scientific advisory services. The Regulation relies on international classification systems and EU directives to define covered activities, and it explicitly captures both direct and indirect provision of services, creating a compliance landscape in which how, where and for whose benefit a service is delivered determines legality.

The January 2026 CSSF Newsletter No 300 highlights a critical and growing nexus between online child sexual exploitation (OCSE) and the movement of funds across financial systems. Increasingly, criminal networks and individual offenders are monetising abuse through live-streaming, extortion and ancillary services, using low-value, high-frequency payments and modern payment rails that can cross multiple jurisdictions in minutes. For banks, payment service providers, virtual asset service providers (VASPs) and other obliged entities, recognising the financial traces of these crimes is a duty that directly supports victim protection and wider anti-money laundering objectives.

The European Union is a major exporter of technology that can have both civilian and military applications. Regulation (EU) 2021/821 provides a comprehensive framework for controlling exports, transit and brokering of dual‑use items, but recent experience and the patterns of trade show persistent gaps when goods move to conflict‑affected regions. The risks are twofold: listed items that clearly require licences may still be authorised to actors or end uses that contribute to violations of international humanitarian law, and non‑listed, mass‑market components can be procured at scale and incorporated into weapons or surveillance systems with severe human rights consequences. Limited, non‑granular reporting and restrictive legal thresholds for catch‑all controls reduce visibility and blunt the EU’s ability to prevent harmful flows.

The CSSF’s Circular 26/906 (20 January 2026) consolidates Luxembourg rules on central administration, internal governance and risk management for payment institutions, electronic money institutions and account information service providers. While the circular covers broad governance requirements, its practical impact on anti‑money laundering and counter‑terrorist financing (AML/CFT) is material: it tightens expectations about how firms must structure control functions, allocate responsibilities, safeguard client funds and assess risks across delivery channels and third‑party arrangements.

The updated 2026 CSSF sub‑sector risk assessment (SSRA) for Specialised PFS providing trust and company service provider (TCSP) activities reconfirms a clear picture: these professionals remain exposed to high inherent money‑laundering (ML) risk, while supervisory and private‑sector controls have reduced residual risk to a medium level. The document is a practical roadmap for compliance teams, risk officers and senior management who must translate sectoral findings into improved day‑to‑day defensive measures.

Strengthening EU Financial Integrity – What the EBA–AMLA Transition Means for Anti‑Money Laundering and Counter‑Terrorist Financing

The formal transfer of the European Banking Authority’s (EBA) anti‑money laundering and countering the financing of terrorism (AML/CFT) powers to the new Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) marks a decisive shift in the EU’s approach to financial crime. The handover – completed at the turn of 2026 after preparatory steps in 2025 – creates a centralised European authority tasked with completing a harmonised Single Rulebook, coordinating supervision across sectors, and raising the consistency and quality of AML/CFT enforcement across member states. For practitioners, supervised entities and regulators, the transition brings regulatory continuity and new supervisory realities to plan for.

Enhancing the effectiveness of the AML/CFT mechanism – lessons from a horizontal analysis of Mutual Evaluation Reports

A horizontal analysis of 23 Mutual Evaluation Reports (MERs) from the Europe II Regional Group shows a clear pattern: many jurisdictions have the legal and institutional building blocks required by the FATF, but operational implementation often lags. The review focuses on Immediate Outcome 6 (use of financial intelligence),Immediate Outcome 2 (international cooperation), and Recommendations 29 and 40. Its purpose is not to judge individual countries, but to surface recurrent strengths, recurring weaknesses, and practical recommended actions that can be pursued regionally and nationally to improve real-world AML/CFT results.

Early insights into dealing with and preventing financial crime

Boards and individual directors are increasingly experimenting with AI tools to prepare for meetings, surface strategic insights and monitor organisational risks. While many of these applications can improve the speed and breadth of oversight, they also create new channels through which financial crime risks can emerge or be obscured. For financial crime practitioners and those advising boards, it is now essential to understand not only how management deploys AI in operations but how directors and boards are using AI in their governance role – and what that means for detection, prevention and legal accountability.

The Financial Intelligence Unit’s Guideline on the Freezing of Suspicious Transactions (Version 2.1.1, applicable from 01/04/2021 and updated 06/01/2026) clarifies how professionals subject to Luxembourg’s AML/CFT Law must behave when they know, suspect or have reasonable grounds to suspect that a transaction is linked to money laundering, a predicate offence or terrorist financing. The guideline reiterates that the freezing order is an exceptional investigatory tool intended to interrupt potentially illicit flows and to give the FIU time to analyse and, where necessary, to pass information on to judicial authorities. It is not a substitute for criminal proceedings and does not determine criminal guilt or legality of transactions.

The Financial Intelligence Unit (FIU) of Luxembourg published Version 2.2 of its Suspicious Operations Report guideline, effective 6 January 2026. The guideline replaces the prior FIU document from 2018 and clarifies expectations for all professionals subject to the Luxembourg AML/CFT Law. It reiterates that any professional, their directors or employees who know, suspect or have reasonable grounds to suspect money laundering, an associated predicate offence or terrorist financing must report without delay, supplying all supporting information and documents that gave rise to the suspicion. The reporting duty applies whether the operation is complete or merely attempted and irrespective of transaction value or whether the predicate offence can be determined.

The past decade has shown that terrorist financing is not an abstract concept but a persistent, adaptive practice exploiting both legal and illicit channels. Recent arrests and marathon trials underscore a frustrating truth for investigators and courts: proving that money sent from Germany actually reached a terrorist group – and tying it to specific crimes – remains difficult. Meanwhile, extremists leverage small donations, social media, crypto, and informal money networks to keep operations alive.

Santa Claus runs an immense, intricately organized operation that offers a rich source of examples for preventing financial crime. If you look closely at how his workshop functions, the techniques, habits, and norms at the North Pole read like a manual for robust safeguards – except they come wrapped in songs, stories, and a lifetime of goodwill. Below are aspects of Santa’s world that, taken seriously, reveal practical, human-centered ways to reduce fraud, abuse, money laundering, terrorist financing, proliferation financing, corruption, and scams.

Artificial intelligence and deepfake technologies are no longer futurist curiosities; they are active tools in the hands of criminals and a growing threat to anti-money laundering, counter‑terrorist financing and counter‑proliferation efforts. The FATF’s 2025 horizon scan makes clear that these capabilities change both how illicit actors operate and how obliged entities and authorities must respond. The challenge is twofold: criminals use AI to scale and hide illicit activity, while legitimate institutions must rapidly adopt equally sophisticated measures to detect and deter misuse without sacrificing access or privacy.

On 19 December 2025 Luxembourg adopted a law amending the Commercial Code and the Companies and Accounting Act to transpose Directive (EU) 2019/1151 on the use of digital tools and processes in company law. While the directive targets digitalisation, the practical effect in Luxembourg is a marked strengthening of registry controls and information sharing aimed at preventing persons subject to judicial bans from occupying management or representative functions. These changes create important new compliance obligations for companies, their service providers and gatekeepers, and they sharpen enforcement pathways where banned persons remain involved in corporate activity.

The European Union’s consolidated FAQs on sanctions against Russia, updated through December 2025, set out detailed operational rules that matter for compliance, risk assessment and investigations. Three interlocking areas are particularly relevant for financial crime practitioners:

• the phased diamond import ban and traceability regime,
• new notification and authorisation rules for movements of Russian diplomatic personnel, and
• prohibitions and withdrawal obligations relating to certain Russian special economic zones.

Understanding the documentary requirements, certification channels, grandfathering rules and enforcement exposure is essential for transaction monitoring, client due diligence, trade-finance screening and sanctions risk remediation.

On 26 February 2025 the Luxembourg Court of Appeal handed down a decision that rekindles an old but still unsettled tension: when can the same conduct give rise to both administrative sanctions imposed by the financial regulator (CSSF) and criminal prosecution for money‑laundering and terrorist‑financing offences, without violating the non bis in idem principle? The Government’s written reply of 16 December 2025 from the Ministers of Justice and Finance to a parliamentary question clarifies how Luxembourg reads that decision in light of EU law and European human‑rights jurisprudence, and outlines the legal and operational framework intended to prevent unwanted collateral effects on criminal enforcement.

Artificial Intelligence has made online financial frauds and scams more convincing and harder to detect. What used to be obvious red flags are now masked by synthetic voices, AI-generated videos and images, highly personalised messages and fake websites that mimic the look and tone of legitimate organisations. Criminals use these tools for impersonation, phishing, investment and insurance frauds, romance scams, purchase frauds and crypto-related schemes. They reach victims through social media, messaging apps, emails and phone calls that often sound realistic because AI helps craft scripts and clone voices. The result is higher emotional pressure on victims, faster manipulation cycles and new techniques – such as look-alike crypto addresses and automated social bots – that amplify trust and urgency.

The 2025 joint report by the European Banking Authority and the European Central Bank synthesizes semi‑annual industry data for H1 2022 through H2 2024 on payment fraud across the EU/EEA. Total reported fraud reached EUR 4.2 billion in 2024, up 17% year‑on‑year. Credit transfers and card payments drove most of the value lost: fraudulent credit transfers amounted to EUR 2.5 billion and card‑related fraud to EUR 1.3 billion. By volume, card fraud dominates: roughly 17 million fraudulent card transactions were recorded in 2024, out of some 111 billion card payments with EU/EEA‑issued cards. Overall fraud rates remain very low relative to transaction volumes and values, but the patterns and distributions of fraud and losses highlight structural vulnerabilities and practical lessons for those fighting financial crime.

The Law of 12 December 2025 introduces a significant amendment to Article 506-1 of the Penal Code, reshaping the legal approach to money laundering and related conduct. By removing the former list of “primary offenses” and replacing it with a global reference to all crimes and offenses, the legislator has opted for a broader and more flexible framework. This reform clearly aims to close gaps that could previously be exploited when proceeds originated from offenses not expressly listed in the law.

Belgium’s evolving anti-money laundering and counter-terrorist financing framework has achieved important legislative and institutional updates since the 2015 evaluation, yet the Financial Action Task Force (FATF) mutual evaluation of early 2025 shows that effectiveness lags behind technical compliance. This discrepancy threatens Belgium’s ability to dismantle organised crime networks, seize illicit assets at scale, and keep pace with rapidly developing threats such as virtual assets. The country has solid building blocks – a capable Financial Intelligence Unit (CTIF), expanded reporting requirements, a beneficial ownership register and recent regulatory reforms – but chronic under-resourcing, uneven supervision of high-risk sectors, gaps in asset recovery, and incomplete frameworks for virtual assets and non-profit organisation risk management hinder practical results.

In 2024 the Luxembourg Financial Intelligence Unit (Cellule de renseignement financier, CRF) continued to sharpen a risk‑based strategy aimed at prioritizing the most significant money‑laundering and terrorist‑financing threats. That strategy rests on a shared understanding of risks between public authorities and the private sector, a stronger analytical capacity inside the CRF, and deeper international cooperation. The CRF supported national and vertical risk assessments driven by the Committee for the Prevention of Money Laundering and Terrorist Financing, and broadened targeted dissemination of a more detailed vertical assessment of terrorist‑financing risks to all professionals registered in the goAML system.

The European Anti‑Money Laundering Authority (AMLA), established by the EU in 2024 and expected to be fully operational by 2028, is designed to unify a fragmented continental approach to anti‑money laundering and countering the financing of terrorism (AML/CFT). For decades the EU’s decentralized supervisory model produced divergent national interpretations, inconsistent enforcement and regulatory gaps that criminal networks exploited. AMLA aims to change that by centralizing key supervisory functions, issuing binding technical standards via the AML Regulation (AMLR), directly supervising a select group of high‑risk cross‑border institutions and coordinating national authorities and financial intelligence units (FIUs) across all 27 member states. The result should be greater legal certainty for institutions operating across borders and a stronger, more coherent European voice in global AML/CFT fora.

Encrypted phones, private militias, maritime logistics and brutal enforcement: investigations show the Balkans-origin criminal networks operate like multinational supply-chain enterprises – only their product is cocaine and their profits are laundered through violence. The Sky ECC leak and multi‑jurisdictional law enforcement work pulled back the curtain on a modern, industrialized drug trade that reaches from Colombian jungle labs to ports in Europe, with key managerial functions carried out by diaspora actors in Western Europe.

Shifting patterns, not a collapse: the new Basel AML Index shows modest improvement in the global average score, but the story beneath the headline is mixed. The 14th Public Edition (December 2025) widens coverage to 177 jurisdictions, tightens risk categories and highlights where vulnerabilities are deepening – especially around financial transparency and the new challenges posed by virtual assets.

Article 6b of Regulation (EU) No 833/2014 imposes concrete information and cooperation duties on natural and legal persons, while explicitly safeguarding the confidentiality of communications between lawyers and their clients. For financial crime and sanctions professionals, this provision is central: it shapes how information must flow to authorities, where the boundaries of legal privilege lie, and how risks around non‑compliance should be managed.

The European Commission has taken a significant step in its fight against financial crime by adding Russia to the EU list of high-risk third countries with strategic deficiencies in their anti-money laundering and counter-terrorist financing (AML/CFT) frameworks. For banks, payment institutions, fintechs, and other obliged entities, this is more than a political signal; it has direct, practical consequences for risk management and day-to-day compliance.

The Financial Action Task Force (FATF) consolidated and updated its processes and procedures for mutual evaluations and follow‑up in the Universal Procedures adopted in October 2023 and updated in December 2025. Those procedures set the common playbook for all AML/CFT/CPF assessment bodies – the FATF itself, FATF‑Style Regional Bodies (FSRBs), and (International Monetary Fund) IMF and World Bank staff who perform assessments – and govern how jurisdictions are assessed, how follow‑up is carried out and how the International Co‑operation Review Group (ICRG) operates. The document clarifies sequencing, roles and responsibilities, team composition, risk‑based scoping, timelines for deskwork and on‑site activity, and the post‑plenary quality and consistency mechanisms that safeguard the FATF brand.

The FATF’s updated Procedures for Mutual Evaluations, Follow‑Up and ICRG, published December 2025, clarify how countries will be assessed for compliance with AML/CFT/CPF standards, how follow‑up is managed and when jurisdictions are escalated to the International Co‑operation Review Group (ICRG). For financial crime practitioners in banks, compliance teams, regulators and advisory firms, the changes and procedural detail matter because they shape international peer pressure, timelines for remedial action, and the likely public signals that affect correspondent relationships, enhanced due diligence and country risk assessments.

The European Union has taken a major step towards a more unified and forceful response to corruption, with negotiators from the European Parliament and the Council reaching a provisional agreement on the EU’s first directive harmonising criminal laws to fight corruption. For compliance teams, financial institutions, and anyone working in financial crime prevention, this deal signals a tightening landscape and a move towards more consistent enforcement across the bloc.

At its 101st Plenary Meeting (Strasbourg, 18, 19 and 21 November 2025), chaired by President David Meyer, the Group of States against Corruption (GRECO) focused its attention on three interlinked priorities: improving the speed and visibility of member states’ compliance with anti‑corruption recommendations, reinforcing mechanisms for integrity at sub‑national levels and in law enforcement, and increasing transparency around GRECO’s own outputs. The adopted Programme of Activities for 2026 formalises these priorities while allowing flexibility to respond to unforeseen scheduling needs.

The Luxembourg supervisory authority (CSSF) recently completed a thematic review focused on counter-proliferation financing controls across five Luxembourg-based investment fund managers (IFMs). The review targeted the specific risk that fund investments might be used to raise, move or make available economic resources that contribute to the proliferation of weapons of mass destruction (WMD). The CSSF examined exposure at asset level with emphasis on dual-use goods (DUGs) and investments in vessels, shipping and other transportation means. The assessment considered risks linked to North Korea, Iran and non-country-specific sanctions regimes and was carried out in the context of FATF’s enhanced expectations on proliferation financing risk assessment and mitigation, together with Luxembourg’s Law of 19 December 2020 implementing restrictive financial measures.

Public procurement is a core state activity and a prime vulnerability for large‑scale corruption and fraud. While EU procurement directives provide a strong legal backbone for above‑threshold contracts, most procurement value and activity falls outside their direct scope. That gap leaves room for inconsistent national practices, artificial contract splitting, excessive use of direct awards and weak monitoring of implementation. To reduce inflated costs, low‑quality delivery and resource misallocation, policymakers must extend effective oversight beyond headline thresholds, accelerate digital and analytical reforms, and tighten accountability around non‑competitive awards. The recommendations below focus on realistic, cost‑sensitive actions that increase detection, deter abuse and improve cross‑border comparability.

The Financial Action Task Force (FATF) plenary in October 2025 produced a set of declarations with direct operational implications for financial institutions, compliance teams and national authorities. The FATF reiterated calls for counter‑measures against jurisdictions with persistent strategic deficiencies in anti‑money laundering and counter‑terrorist financing (AML/CFT) regimes and urged proportionate enhanced vigilance for other high‑risk jurisdictions. This article summarizes the FATF’s October 2025 positions, explains practical implications for compliance and reporting processes, and highlights immediate actions firms should take to align with the FATF guidance.

Germany’s political stability, large economy and cultural preference for cash have made it an unexpectedly attractive destination for money launderers. Criminals – from drug cartels to human trafficking networks, corrupt officials and even terrorist supporters – exploit gaps in oversight and everyday practices to turn illegally earned cash into apparently legitimate wealth. The result is a widespread system in which illicit funds are integrated into local businesses, real estate and luxury goods markets, distorting competition, depriving the state of tax revenue and financing further serious crime. Beyond these headline effects, a number of structural and practical factors compound the problem. The absence of a comprehensive national cash ceiling and the slow rollout of EU mandated limits leave high value cash transactions relatively easy to conduct and justify. Incomplete company ownership transparency and patchy enforcement of beneficial ownership registries allow opaque corporate vehicles and nominee directors to shield the true beneficiaries of suspicious flows. Professional services – lawyers, notaries, accountants and real estate agents – operate within complex liability regimes that make it difficult to detect or prove willful facilitation; in some cases, genuine ignorance or procedural gaps prevent timely reporting. At the operational level, cross border courier networks, prepaid and disposable telephony, and sophisticated layering techniques such as micro deposits through many small accounts or the purchase and re sale of high value movables (art, watches, cars) let launderers rapidly sever paper trails. Moreover, the sheer size and liquidity of German markets create ample opportunities to absorb and legitimize large sums without immediate market disruption, while social and bureaucratic trust in documentation encourages authorities and private actors to accept formal paperwork at face value. Taken together, these features make Germany not merely a passive corridor for illicit capital but an active destination where dirty money can be concealed, multiplied and reinvested with relatively low short term risk for the perpetrators.

The Council of Europe’s Committee on the Evaluation of Anti‑Money Laundering Measures and the Financing of Terrorism concluded its 5th round of mutual evaluations, published final reports for the last group of assessed jurisdictions and became the first body in the FATF Global Network to launch on‑the‑ground work under the FATF’s revised 6th‑round methodology. Those twin developments — finishing a long evaluation cycle while initiating a new one structured to place greater emphasis on measurable outcomes and contextual risks — make 2024 a watershed moment for European AML/CFT peer review.

Recent months have reinforced that terrorist financing is evolving rapidly: methods are becoming more fragmented, hybrid and digital, while perpetrators exploit legal gaps in crowdfunding, virtual asset services and long chains of intermediaries. Financial Intelligence Units (FIUs) have flagged the same themes seen across Europe and globally — small recurring payments, peer‑to‑peer transfers, mixed use of informal value transfer systems and crypto, and the use of legitimate‑looking organisations and platforms as conduits. These developments increase the risk that seemingly benign transactions will form parts of broader financing networks.

EBA Closes AML/CFT Chapter as AMLA Takes the Helm: What Changes for EU Financial Crime Control

A coordinated handover from the European Banking Authority (EBA) to the new Anti-Money Laundering Authority (AMLA) marks a major shift in how the EU will fight financial crime. The transition consolidates AML/CFT powers, reshapes supervisory cooperation, and sets up a more consistent framework for enforcement, risk assessment, and information sharing.

The draft Regulatory Technical Standards (RTS) supplementing Regulation (EU) 2024/1624 set out a detailed, risk-sensitive framework for customer due diligence (CDD) across the European Union. The text aims to standardise what information obliged entities must collect, how identity and beneficial ownership should be verified, and when simplified or enhanced measures apply. That harmonisation objective runs through the draft: the same basic approach applies to natural persons and legal persons, and Member States and obliged entities are expected to align their practices with the common parameters the RTS defines.

The European Banking Authority’s October 2025 response to the European Commission’s Call for Advice provides a compact, operational blueprint for multiple technical mandates that will underpin the European Anti‑Money Laundering Authority’s early work. The EBA advances a risk‑based and proportionate approach across four draft regulatory technical standards and offers technical advice on two additional mandates: base amounts for pecuniary fines and minimum standards for group information‑sharing. The package is designed to deliver comparable outputs for supervisors while allowing AMLA time to phase in requirements and for obliged entities to adjust.

A decisive shift in global efforts against illicit finance marked the conclusion of the fourth Plenary meeting under the Mexican Presidency of Elisa de Anda Madrazo in Paris on 24 October 2025. Delegates from more than 200 jurisdictions and observers within the FATF Global Network met over three days to drive a tighter focus on depriving criminals of their proceeds and safeguarding the international financial system from emerging threats, including those posed by artificial intelligence and deepfakes.

The European Union’s 19th sanctions package, adopted on 23 October 2025, represents a major step up in tactical and structural pressure on Russia’s war economy. The measures notably combine an unprecedented energy embargo with targeted financial restrictions (including the first explicit crypto measures), expanded trade controls against the military‑industrial base, and strengthened anti‑circumvention tools that reach third‑country enablers. For financial crime practitioners, compliance officers and investigators, the package broadens the list of sanctioned counterparties, tightens transaction prohibitions, and expands mechanisms for identifying and disrupting opaque value chains such as the oil shadow fleet and offshore crypto conduits.

A resilient fund ecosystem, sharpening competition with Ireland, and a cautious stance on centralized EU oversight: Luxembourg’s financial watchdogs outlined a market in transition, with tax receipts rising and supervisory philosophy firmly rooted in pragmatism.

The European Banking Authority’s Report on the Functioning of AML/CFT Colleges in 2024–25 is the final assessment the EBA will publish before responsibility for monitoring colleges transfers to the European Anti-Money Laundering Authority (AMLA) on 1 January 2026. Covering 1 January 2024 to 31 May 2025, the report assesses how the permanent supervisory structures for cross-border firms are working, summarises EBA monitoring activity, and tracks progress against six action points the EBA has promoted since colleges began in 2020. The findings are pragmatic: the colleges framework is now established and operational across the EU, but meaningful improvements are still required if colleges are to deliver coordinated, risk-focused supervision of cross-border financial crime risks.

The European Union’s system for controlling dual-use exports — goods, software and technologies that can serve both civilian and military purposes — is no longer a niche trade compliance topic. It has become an active instrument of economic security with direct implications for sanctions screening, transaction monitoring, beneficial ownership investigations and anti-circumvention enforcement. The 2025 updates to Annex I of Regulation (EU) 2021/821 and parallel Commission initiatives expose new vulnerabilities for illicit financial flows, new compliance obligations for firms and new opportunities for investigators to detect and disrupt diversion routes that feed warfare, repression and proliferation.

The European Banking Authority’s 2024 supervisory convergence review shows that EU supervisors continued to tighten and align prudential, resolution and digital-finance oversight while increasing focus on anti‑money laundering and countering the financing of terrorism (AML/CFT). For practitioners and compliance teams this matters: supervisory convergence reduces opportunities for regulatory arbitrage, concentrates supervisory scrutiny on common weaknesses, and creates practical expectations that banks, asset managers, fintechs and crypto‑asset firms must meet. This article extracts the AML/CFT implications from the EBA’s report and sets out what firms and compliance officers should prioritise now.

The European Banking Authority’s October 2025 report on tackling money‑laundering and terrorist‑financing risks in crypto‑asset services consolidates hard lessons from recent supervisory cases across the EU. MiCA and the strengthened AML/CFT framework already provide a far more consistent EU rulebook than existed before 2024, but the report shows that many practical vulnerabilities persist. Unauthorised operations, forum shopping, misuse of the reverse‑solicitation carve‑out, weak compliance by group structures, opaque ownership and multi‑entity workarounds continue to expose the market and consumers to ML/TF risks — and they can propagate rapidly once a CASP is authorised and passporting begins.

The European Banking Authority’s final implementation report draws a clear line under a six‑year programme of reviews of national competent authorities’ (NCAs) approaches to anti‑money laundering and countering the financing of terrorism (AML/CFT) supervision of banks. Between 2018 and 2024 EBA teams assessed 40 NCAs across EU/EEA states, fed back findings, and issued targeted recommendations. The October 2025 stocktake summarises what those NCAs have done in response and hands an up‑to‑date picture to the new EU Anti‑Money Laundering Authority (AMLA).

The European Commission has told the three European Supervisory Authorities (EBA, ESMA, EIOPA) and the Anti‑Money Laundering Authority (AMLA) that it will not adopt 115 Level‑2 implementing and delegated acts deemed non‑essential before 1 October 2027. These measures come from empowerments included in Level‑1 legislation adopted between 2019 and 2024. The Commission’s stocktake found roughly 430 empowerments in the acquis across financial services; 115 of those have been classified as not necessary for the effective functioning of the underlying Level‑1 rules or for achieving EU policy goals. Where Level‑1 acts impose deadlines to adopt Level‑2 rules, the Commission says it will propose amendments or repeals as part of forthcoming Level‑1 reviews.

This article explains the main obligations for financial sector professionals operating under Luxembourg law when confronted with international financial sanctions. It translates legal and supervisory requirements into practical steps firms must adopt to remain compliant, avoid enforcement action and limit operational disruption.

The Commission de Surveillance du Secteur Financier (CSSF) has introduced targeted updates to the AML/CFT Market Entry Form (MEF) to streamline the collection of standardized information on money laundering and terrorist financing (ML/FT) risks. The MEF remains mandatory for Funds that are or will be authorised (including ELTIFs, regardless of their AIF type) and for Investment Fund Managers (IFMs) that are or will be authorised or registered and supervised by the CSSF for AML/CFT purposes. The changes refine when the form must be filed and what information is required, while reinforcing expectations around governance and timely submission.

The EU’s 29 September 2025 package reimposes nuclear-related sanctions on Iran after the UN snapback process was triggered by the E3. For financial crime teams, this resets screening, KYC, and transaction monitoring baselines to a pre-2016 posture — while adversaries are far more sophisticated than they were in 2012–2015. The default outcome of UN snapback under Resolution 2231’s reverse‑veto design means institutions must assume full restoration of prior UN measures complemented by EU autonomous restrictions, with immediate effect and negligible grace periods.

From 22 to 26 September 2025, Luxembourg hosted a delegation from the Council of Europe’s Group of States against Corruption (GRECO) as part of its 6th Round Evaluation. The visit formed part of GRECO’s ongoing work to strengthen integrity and prevent corruption, with the current evaluation cycle focusing on the sub-national level.

A coordinated push by the European Commission to strengthen the fight against money laundering and terrorist financing is underway, as Brussels launches infringement procedures against several EU countries that missed a key legal deadline to ensure comprehensive access to beneficial ownership information. The move underscores the Commission’s resolve to close transparency gaps that can be exploited by criminal networks and to align national frameworks with EU standards.

Understanding why ownership and control matter

Complying with EU restrictive measures means more than screening names against a list. It requires recognising when an entity is owned or controlled by a Listed Person, even if that entity is not itself named on a sanctions list. Listed Persons often structure their interests to obscure control through layers, trusts, nominees, or agreements. If you fail to identify this, you risk breaching sanctions by dealing with an entity whose assets should be frozen or to which funds cannot be made available, even indirectly. This article explains the legal framework, how “ownership” and “control” are assessed in practice, how presumptions can be rebutted, and what steps you can take to manage risk, including when and how to leverage the EU Sanctions Helpdesk.

Overview of key developments and supervisory priorities

The European Banking Authority’s AML/CFT Newsletter Issue 16 (2025) highlights supervisory trends, risk drivers and practical expectations for obliged entities and competent authorities across the EU. The Newsletter reiterates that effective risk-based approaches, governance and cooperation remain central to the EU’s framework as Member States implement the AML/CFT Package and the AML Authority (AMLA) continues to mature. Observed weaknesses in customer due diligence (CDD), transaction monitoring and beneficial ownership verification are drawing continued supervisory focus, alongside evolving threats from virtual assets, trade-based money laundering and misuse of legal persons and arrangements.

The growth of fiat‑backed stablecoins creates important opportunities and distinct financial crime challenges for financial institutions providing banking services to issuers. Although stablecoins offer price stability, rapid settlement and broad reach that benefit legitimate users, those same attributes — together with pseudonymous blockchain transactions — can be misused by criminals and sanctions‑evaders to obtain currency‑denominated value outside traditional rails. Banks must therefore treat relationships with stablecoin issuers like other higher‑risk correspondent or PSP relationships while adapting controls to the technical and operational features specific to stablecoins and distributed ledger activity.

The FATF/Egmont/INTERPOL/UNODC handbook (2025) emphasises that tackling contemporary money laundering requires a calibrated mix of informal and formal international cooperation.

As investigators move from detection to investigation and prosecution, informal cooperation should be used to sharpen formal requests, confirm whether coercive powers will be needed, and prepare admissible evidence.

The FATF Money Laundering National Risk Assessment Toolkit (Annexes A–C) provides focused, practical guidance for jurisdictions confronting some of the most challenging elements of modern ML risk: corruption, virtual assets and VASPs, opaque legal persons and arrangements, and the informal economy. It emphasizes that NRAs are not one-size-fits-all: countries must adapt methods to local context, document assumptions and data gaps, and engage both public and private stakeholders to collect and validate evidence. The Toolkit lays out concrete data sources — from STRs and tax records to court judgments, procurement data and blockchain analytics — and offers case studies and checklists for drilling into sectoral vulnerabilities and typologies.

Annex C maps fit-for-purpose assessment instruments — World Bank, IMF and Council of Europe tools — while Annex A supplies quick guides for difficult thematic areas. Across the package the message is consistent: produce manageable, accessible NRAs that prioritize where risk is highest, enable proportionate supervisory and legislative responses (for example, BO registries or VASP regimes), and include monitoring and review processes so risk understanding, controls and enforcement evolve alongside new technologies and cross-border threats.

The CSSF continued to apply a risk‑based supervisory framework combining off‑site and on‑site measures to monitor compliance with anti‑money laundering and countering the financing of terrorism obligations. In 2024 the authority collected quantitative and qualitative data through the annual Questionnaire on Financial Crime across all supervised sectors, implemented an API to streamline data intake and processed long‑form audit and AML/CFT reports from approved statutory auditors and internal control functions. The CSSF placed particular emphasis on the quality of name screening, timely review of alerts, transaction monitoring effectiveness, beneficial owner identification and documentation of source of funds and wealth. The regulator also stressed the need for clear governance of outsourced AML/CFT tasks and robust second‑line controls.

Why terrorists adopt and adapt technology

Terrorist groups and individuals adopt new technologies when those tools help them meet basic needs: raising and moving money, communicating with supporters and adversaries, planning and carrying out attacks, and amplifying their actions for propaganda value. Decisions to adopt a specific technology are driven by internal factors such as strategy, organisation and individual skills, and by external factors such as available resources, relationships with other actors and the effectiveness of countermeasures. Strategic priorities — for example whether a group values secrecy or reach — shape whether adoption favors covert tools like encryption or open platforms that give wider visibility. Organisational form matters too: hierarchical groups may invest in long-term, complex programs, while loosely networked or individual actors rapidly exploit accessible consumer technologies.

The Wolfsberg Group’s Part II Statement on Effective Monitoring for Suspicious Activity argues that financial institutions must shift from legacy, rules-based transaction monitoring to monitoring strategies that prioritise measurable outcomes, quality of leads to law enforcement, and the use of advanced analytics. The document frames this transition around three pillars — transition and validation, balancing model risk with financial crime risk, and explainability — and emphasises that modern monitoring should integrate customer behaviour and non-transactional signals alongside transactions. Importantly, the Group recognises that many older systems produce high volumes of low-value alerts and that new approaches should be tailored to identify higher-quality suspicious activity even if they do not replicate every output of legacy systems.

Accounting manipulation represents one of the most sophisticated and damaging forms of financial crime today, undermining investor confidence, distorting market efficiency, and sometimes precipitating the collapse of entire corporations. While some accounting practices fall within legal boundaries — often referred to as creative accounting — illegal manipulations deliberately misrepresent a company’s financial condition, thereby deceiving stakeholders and regulators alike. This article provides a comprehensive examination of the motives, methods, detection techniques, and consequences of accounting manipulations, emphasizing the need for heightened awareness and expertise in the fight against financial crime.

Artificial intelligence (AI) is rapidly transforming organizational landscapes, offering opportunities for enhanced efficiency and innovation. However, with this transformation comes a critical need to manage the ethical implications associated with AI use. A practical guide on managing AI ethics, provided by The Ethics Institute (TEI), emphasizes a human-centered approach that balances what is good for individuals and society, aiming for collective flourishing. This guide focuses on how organizations can responsibly integrate AI while mitigating risks.

The growth of cryptoassets on permissionless public blockchains has outpaced the ability of traditional AML frameworks to contain illicit flows. The Bank for International Settlements Bulletin No. 111 (13 August 2025) proposes a practical alternative: leverage the public, tamper-evident transaction history on blockchains to compute AML compliance scores tied to specific units (UTXOs) or wallets and apply those scores where crypto intersects with the banking system. This article summarises the BIS proposal, explains how such scoring would work for different token types, reviews implementation choices and incentives, and highlights the key policy trade-offs for regulators, financial institutions and crypto service providers.

The European Banking Authority (EBA) has released a comprehensive report evaluating the current state and future potential of supervisory technology (SupTech) in combating money laundering and terrorist financing across the European Union. This assessment comes at a pivotal time as the EU rolls out a revamped anti-money laundering and countering the financing of terrorism (AML/CFT) framework, highlighted by the creation of the Anti-Money Laundering and Countering the Financing of Terrorism Authority (AMLA). This new authority is tasked with coordinating AML/CFT supervision across member states, aiming for consistent application of rules and increased cooperation.

The Group of States against Corruption (GRECO) published its Second Compliance Report assessing Germany’s progress on 14 recommendations from the Fifth Evaluation Round, which focuses on preventing corruption and promoting integrity in central government top executive functions and in law enforcement agencies. The compliance review covers measures taken since GRECO’s original evaluation in 2020 and the first compliance review in 2022. The German authorities submitted a Situation Report in September 2024; GRECO adopted its Second Compliance Report in March 2025 and made it public in August 2025. The report finds meaningful reforms in some areas – notably lobbying transparency, codes of conduct in police agencies and whistleblower protection – but identifies persistent gaps in oversight of political executives, financial disclosure, proactive police monitoring and recruitment screening.

Since June 2024, European Union individuals and businesses with ownership or control over entities outside the EU have been facing new responsibilities when it comes to enforcing sanctions against Russia and Belarus. The EU requires these operators to use “best efforts” to ensure that their foreign affiliates do not undermine the effectiveness of EU sanctions — even if those affiliates are outside the EU’s legal reach.

The recent FATF webinar on complex proliferation financing (PF) and Sanctions Evasion Schemes presented a detailed overview of the evolving challenges and strategies used by state and non-state actors to circumvent international sanctions related to weapons of mass destruction (WMD) programs.

Circular No. 792 ter enhances customer identification and verification requirements for AML/CFT compliance among AED-Supervised Professionals in Luxembourg

Circular No. 792 ter, issued on July 28, 2025, updates the obligations of professionals subject to the control and supervision of the Administration de l’Enregistrement, des Domaines et de la TVA (AED) in Luxembourg in the fight against money laundering and terrorist financing. This circular reinforces the requirements for identifying and verifying the identity of individual customers, in line with the amended law of November 12, 2004, which governs anti-money laundering and counter-terrorism financing (AML/CFT) measures.

The European Banking Authority (EBA) is empowered by Article 6(5) of Directive (EU) 2015/849 to deliver an Opinion every two years on the risks related to money laundering (ML) and terrorist financing (TF) within the EU’s financial sector. This fifth Opinion spans data collected from January 2022 to December 2024 and is intended for European co-legislators as well as AML/CFT competent authorities. The purpose of this Opinion is to guide competent authorities in applying a risk-based approach to AML/CFT supervision and to inform the European Commission’s supranational risk assessment frameworks.

The European Banking Authority’s 2025 Opinion on money laundering (ML) and terrorist financing (TF) risks within the EU financial sector highlights significant developments and challenges related to collective investment schemes and fund managers. These entities, which play a crucial role in managing assets on behalf of investors, face evolving ML/TF risks driven by changes in financial markets, regulatory expectations, and emerging criminal tactics.

The webinar centered on the release and discussion of a comprehensive update on terrorist financing (TF) risks, marking the first significant review since 2015. The session provided a detailed examination of the evolving landscape of terrorist financing, highlighting how the methods, channels, and risks have shifted over the past decade. It aimed to inform a broad audience, including policymakers, law enforcement officials, private sector representatives, academics, and civil society actors, about current trends and emerging threats in order to strengthen collective efforts against terrorist financing.

The Wolfsberg Group has emphasized the critical role of the risk-based approach (RBA) in designing and maintaining effective financial crime risk management (FCRM) programs within financial institutions (FIs). This approach shapes an FI’s risk appetite, policies, measures, and controls, making it a cornerstone of combating financial crime.The Group first highlighted the importance of RBA in 2006 with its paper Guidance on an RBA for Managing Money Laundering Risks. Since then, the concept has gained widespread recognition across both private and public sectors. In response to ongoing regulatory reform and evolving standards, the Wolfsberg Group has decided to clarify the essential elements that constitute an effective RBA.

The EU has adopted its 18th sanctions package against Russia — its toughest to date — targeting energy, banking, and the military-industrial complex, with complementary measures on Belarus. For compliance, sanctions, and financial crime professionals, this package expands exposure across vessels, banks, software, commodities, and third-country intermediaries.

The Financial Action Task Force (FATF) plays a crucial role in safeguarding the global financial system against money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction. To achieve this, FATF develops and promotes international standards known as the FATF Recommendations, which are globally recognized as the benchmark for Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT).

The Financial Action Task Force (FATF), an independent inter-governmental body, plays a critical role in safeguarding the global financial system from money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction. Its updated Procedures for Anti-Money Laundering, Countering the Financing of Terrorism, and Countering the Financing of Proliferation (AML/CFT/CPF) Mutual Evaluations, Follow-Up, and International Cooperation Review Group (ICRG) processes, last revised in June 2025, provide a comprehensive framework for assessing and monitoring countries’ compliance with FATF Standards.

The document titled “Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up (‘Universal Procedures’), June 2025,” issued by the Financial Action Task Force (FATF), outlines the standardized procedures and processes to be followed by all Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) assessment bodies. These include FATF itself, FATF-style regional bodies (FSRBs), and International Financial Institutions (IFIs) such as the IMF and World Bank.

The Financial Action Task Force (FATF) has outlined comprehensive procedures for its fourth round of mutual evaluations focused on anti-money laundering (AML) and countering the financing of terrorism (CFT). These procedures, updated as of June 2025, establish a rigorous framework to assess FATF members’ compliance with global AML/CFT standards, which are critical to safeguarding the international financial system.

The year 2025 marks a milestone in the European Union’s coordinated efforts to combat money laundering (ML) and terrorist financing (TF) with the operational launch of the Anti-Money Laundering Authority (AMLA). Established by Regulation (EU) 2024/1620, AMLA represents a new central EU agency tasked with harmonizing and strengthening AML/CFT supervision and financial intelligence cooperation across the Union. The AMLA Work Programme 2025 articulates the agency’s foundational activities, strategic priorities, and operational roadmap for its inaugural year.

Terrorist financing remains one of the most pressing challenges to global security, as terrorist groups continue to exploit a wide array of financial channels to fund their operations. The Financial Action Task Force’s (FATF) July 2025 report offers an in-depth examination of how these groups adapt to changing environments, blending traditional methods with cutting-edge technologies to evade detection and sustain their activities.

The memorandum of understanding signed on 27 June 2025 formalises practical modalities for cooperation and information exchange between the European Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) and the European Central Bank (ECB). The document establishes a structured framework to ensure timely, efficient and proportionate sharing of supervisory information where the mandates of both institutions intersect, in particular for credit institutions that are subject to both prudential supervision under the Single Supervisory Mechanism (SSM) and AML/CFT oversight under AMLA. The MoU is framed as a statement of intent: it does not create legally enforceable rights but sets out procedures, contact arrangements, confidentiality rules and a list of documents to be shared routinely.

The Multilateral Memorandum of Understanding signed on 27 June 2025 formalises a practical cooperation framework between the Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) and the three European Supervisory Authorities (EBA, EIOPA and ESMA).

The EU Sanctions Helpdesk, launched in 2025, is a new and valuable resource for businesses needing guidance on sanctions compliance and due diligence.Set up on behalf of the European Commission and funded by the Service for Foreign Policy Instruments (FPI), the Helpdesk is part of the wider project “Support to EU SMEs on EU Sanctions Due Diligence.”Its primary goal is to help companies – especially small and medium-sized enterprises – navigate the complex landscape of both UN and EU restrictive measures,ensuring they meet legal obligations and avoid costly compliance errors.

The Financial Action Task Force (FATF) plenary in June 2025 issued a series of declarations that sharpen the international community’s focus on jurisdictions with substantial and strategic deficiencies in anti‑money‑laundering and counter‑terrorist financing (AML/CFT) frameworks. The FATF reiterated calls for targeted counter‑measures against the Democratic People’s Republic of Korea (DPRK) and renewed pressure on Iran, while asking members and other jurisdictions to apply enhanced vigilance measures toward Myanmar and a larger group of countries under increased monitoring. These decisions carry concrete operational expectations for banks, payment providers, and other financial actors – including intensified customer due diligence, enhanced transaction monitoring, and prompt suspicious activity reporting.

In 2019, the Financial Action Task Force (FATF) extended its global standards on anti-money laundering and counter-terrorist financing (AML/CFT) to virtual assets (VAs) and virtual asset service providers (VASPs). This 2025 report provides the sixth targeted review of the implementation of Recommendation 15 (R.15) by FATF jurisdictions worldwide. The FATF Virtual Assets Contact Group’s (VACG) roadmap aims to increase compliance and implementation of these standards.

The Financial Action Task Force (FATF) issued updated guidance in June 2025 to help countries develop anti-money laundering (AML) and counter-terrorist financing (CFT) measures that support financial inclusion without compromising the fight against financial crime. This guidance builds on previous versions and incorporates recent revisions to FATF recommendations, emphasizing the importance of a risk-based approach (RBA) to balance financial integrity and inclusion objectives.

The Financial Action Task Force (FATF) plays a crucial role in safeguarding the global financial system against the risks posed by money laundering (ML), terrorist financing (TF), and proliferation financing (PF) — which involves the funding of weapons of mass destruction. In June 2025, FATF updated its comprehensive methodology used to assess countries’ compliance with its Recommendations and the effectiveness of their Anti-Money Laundering, Countering the Financing of Terrorism, and Countering Proliferation Financing (AML/CFT/CPF) systems. This article outlines key aspects of this updated 5th round assessment methodology, which started implementation in 2024.

The recent FATF report from June 2025 provides a detailed analysis of the increasingly complex methods used by state and non-state actors to finance the proliferation of weapons of mass destruction (WMD) and evade sanctions. This illicit activity poses a significant threat to global security and the integrity of the international financial system. Despite decades of targeted financial sanctions and export controls, proliferation financing (PF) networks remain resilient, exploiting vulnerabilities in national and international systems.

The Financial Action Task Force (FATF) is a crucial inter-governmental organization established in 1989 by ministers from its member jurisdictions. Its primary mission is to set international standards and promote the effective implementation of legal, regulatory, and operational measures aimed at combating money laundering, terrorist financing, the financing of proliferation of weapons of mass destruction, and other threats to the integrity of the global financial system.

The Financial Action Task Force (FATF) has recently revised Recommendation 16 (R.16), a key standard addressing transparency in wire transfers and payment systems. The amendments reflect the rapid evolution in the payment domain, including diverse products, innovative technologies, and complex market participants, while responding to emerging threats such as fraud, which now ranks as a major predicate offense for money laundering. This article explores the key elements of the updated R.16, its implications for financial institutions (FIs), and the broader fight against money laundering and terrorist financing (AML/CFT).

As tax crimes and associated illicit financial flows grow more complex and cross-border, jurisdictions need clear, practical guidance to investigate, prosecute and recover proceeds. A tax crime investigation manual (TCIM) turns strategy into operational practice by compiling legal references, investigative procedures, templates, approval paths and inter‑agency routines into a single, usable resource. Well designed, a TCIM helps investigators act quickly and lawfully, protects suspects’ rights, preserves evidence and assets, and strengthens co‑operation with other domestic and foreign authorities.

Overview and Context

The joint FATF-MONEYVAL Plenary held in Strasbourg on 13 June 2025 delivered a series of consequential decisions that will shape global anti-money laundering, counter-terrorist financing, and counter-proliferation financing efforts for years to come. Chaired by FATF President Elisa de Anda Madrazo and MONEYVAL Chair Nicola Muccioli, the two-day session gathered the FATF Global Network — representing more than 200 jurisdictions and observers — for intensive technical discussions focused on payment transparency, targeted monitoring, financial inclusion, and emerging illicit finance threats.

Why sanctions due diligence matters for EU SMEs

Sanctions due diligence is the process of identifying, preventing and managing potential sanctions risks in your business. For small and medium-sized enterprises (SMEs) operating in the EU, the consequences of getting this wrong range from halted transactions and reputational damage to severe financial penalties and criminal exposure.

The Group of States against Corruption (GRECO) held its centenary plenary in Strasbourg on 3, 4 and 6 June 2025. Chaired by David Meyer, GRECO used the milestone session to review ongoing evaluations, compliance procedures, outreach and institutional partnerships. The meeting reaffirmed GRECO’s role as a central monitoring mechanism for anti‑corruption reform across Council of Europe member states and strengthened ties with international partners, particularly the European Union and OECD. Several practical decisions taken at the plenary carry direct relevance for financial crime prevention, compliance practitioners and policy makers.

EU sanctions are political instruments intended to change or deter behavior and to help maintain or restore international peace and security. They come in different forms — asset freezes, trade and other restrictions, and financial measures — and are designed to apply pressure on targeted governments, entities, individuals, sectors or groups. For small and medium-sized enterprises (SMEs) in the EU, understanding how sanctions work, whose activities are caught and how to operationalize compliance is essential to avoid severe legal, financial and reputational consequences.

EU sanctions are a hybrid of politics and law. For private-sector compliance teams, that duality creates a recurring question: what part of the sanctions framework is mandatory law and what part is acceptable guidance? The EU Sanctions Helpdesk’s Module 2 training on law and guidance provides a clear roadmap that helps practitioners navigate that line and make defensible decisions when transactions touch sanctioned persons, jurisdictions or sectors.

Did you know that AI systems used specifically for Anti-Money Laundering (AML) and fraud detection in financial services are not classified as ‘high-risk’ under the EU AI Act?

The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions establishes a clear, binding framework to criminalise the offering, promising or giving of undue advantages to foreign public officials to obtain or retain business or any other improper advantage. Adopted in 1997 and reinforced by subsequent OECD guidance, the Convention targets the supply side of corruption: the companies, intermediaries and individuals who initiate or sustain bribery in international commerce. Its purpose is pragmatic – to restore fair competition, protect public procurement and infrastructure projects from distortion, and reduce the human and economic harm that flows from corrupt contracts and substandard public services.

The European Union has adopted its 17th package of sanctions against Russia, a move that significantly intensifies pressure on the Kremlin’s wartime economy while tightening the compliance landscape for global shipping, energy, and trade. Framed as the largest single G7 action targeting the “shadow fleet” carrying Russian oil, the package widens restrictions on vessels, expands listings of individuals and entities, and deepens export controls on dual-use and advanced technologies. For financial crime professionals, the package underscores three priorities: choke off Russia’s access to revenue, block battlefield technologies, and harden the system against circumvention.

Introduction to EU sanctions and their objectives

EU sanctions are restrictive measures designed to influence behavior, maintain or restore international peace and security, and prevent further harm. They are primarily preventive rather than punitive: the aim is to change or deter conduct by targeting specific persons, entities, sectors or activities. Sanctions adopted at the EU level either implement United Nations Security Council decisions or are imposed independently by the EU. For financial crime practitioners, recognising that sanctions are legal instruments with both political and operational implications is essential for effective compliance and risk management.

The Commission published a report analyzing stakeholder feedback from public consultations on the AI Act’s regulatory obligations regarding the definition of AI systems and prohibited AI practices, highlighting calls for clearer technical definitions and concrete examples of prohibited activities.

Artificial intelligence (AI) is no silver bullet, but it can materially strengthen the European Union’s capacity to prevent, detect and investigate corruption. Traditional methods struggle with scale: sprawling public procurement records, cross-border asset routes, complex beneficial ownership chains and encrypted communications generate data volumes and patterns that outstrip human processing. AI and machine learning (ML) can sift these data, surface anomalies in near real time, and point investigators to the highest-risk leads. At the same time, unregulated or poorly governed deployments risk privacy violations, unfair bias, opaque decision-making and mission creep. For EU policymakers, the immediate priority is to adopt a balanced approach that captures AI’s operational benefits while embedding robust legal, ethical and oversight safeguards.

Full Implementation of the New Crypto-Asset Framework

As of 31 December 2024, the European Union’s new crypto-asset regulatory framework has come into effect, encompassing the Markets in Crypto-Assets Regulation (MiCAR), the transfer of funds and certain crypto-assets Regulation, and amendments to Directive (EU) 2015/849. Crypto-asset service providers (CASPs) are now mandated to establish rigorous systems and controls to prevent their platforms from being exploited for money laundering and terrorist financing activities. This milestone marks a significant step towards strengthening the EU’s financial crime defenses in the rapidly evolving digital asset sector.

The European Banking Authority (EBA) plays a key role in shaping the European Union’s regulatory landscape for anti-money laundering and countering the financing of terrorism (AML/CFT). The EBA has developed various legal instruments designed to enhance the effectiveness of AML/CFT systems and controls within financial institutions and supervisory bodies across the EU. These instruments adopt a proportionate, risk-based approach focused on cooperation and information-sharing, aiming for consistent application throughout the region.

GRECO’s 99th Plenary Meeting, held in Strasbourg on 17–19 March 2025, reaffirmed the Group of States against Corruption’s central role in monitoring and driving anti‑corruption reforms across Europe and partner countries. The plenary produced a series of decisions and follow‑up measures that signal continuing pressure on member states to implement GRECO’s recommendations, a reinvigorated focus on sub‑national integrity through the launch of the Sixth Evaluation Round, and closer cooperation with other rule‑of‑law bodies and civil society.

Online Child Sexual Exploitation (OCSE) is a rapidly growing global crime that inflicts severe harm on millions of children worldwide. It primarily manifests as live-streamed sexual abuse of children (LSAC) and financial sexual extortion of children (FSEC). Both forms rely heavily on digital payment systems and online platforms, making financial transactions a crucial point for detection, disruption, and investigation. This article consolidates insights on financial indicators linked to OCSE, investigative approaches, and strategies to combat these crimes.

High-level corruption remains a persistent threat to good governance, public trust and economic development. The FALCON Project’s policy brief synthesizes evidence from 63 corruption cases across more than 40 countries and presents an empirical picture of how grand corruption, procurement fraud, border corruption and sanctions circumvention operate in practice. This article distills the brief’s main findings about offence types, money flows, transnational patterns, measurable risk indicators, socioeconomic impacts and concrete policy responses that can reduce opportunities for abuse.

The Financial Action Task Force (FATF) plenary in February 2025 produced a set of declarations and calls to action that carry immediate implications for compliance teams, financial institutions and regulators. The latest communiqué highlights jurisdictions with substantial strategic deficiencies in anti–money laundering and countering the financing of terrorism (AML/CFT), renews calls for counter‑measures against the Democratic People’s Republic of Korea (DPRK) and Iran, and reiterates expectations for enhanced vigilance with respect to a broader list of higher‑risk countries. This article summarizes the key points of the FATF statement, explains the operational implications for firms, and sets out practical next steps compliance officers should adopt now.

How the 2025 Global Terrorism Index reshapes financial crime risk assessment

The Global Terrorism Index 2025 (GTI 2025) presents a changing picture of where and how terrorism is concentrated, the actors driving violence, and the technologies transforming operational capabilities. For professionals in financial crime compliance, fraud investigation, sanctions enforcement, and counter–terrorist financing (CTF), the report contains several implications that require immediate reassessment of risk models, transaction monitoring rules, customer due diligence (CDD) processes, and intelligence-sharing priorities. This article translates the GTI 2025’s findings into practical considerations for financial crime teams and senior decision‑makers.

The European Union has adopted its 16th sanctions package against Russia, intensifying pressure as the invasion of Ukraine enters its fourth year and tightening controls on circumvention channels that have evolved since early measures were introduced. This package reflects a clear shift from broad trade and financial restrictions toward highly targeted interventions that aim to disrupt specific revenue streams, choke off critical technologies and services used in the war effort, and neutralize evasive tactics across maritime, financial, logistics, energy, and media domains. For compliance teams and financial crime professionals, the package signals a significant step-up in risk exposure across supply chains, shipping, commodity trade finance, technology exports, correspondent banking, and crypto asset services.

A recalibrated risk-based approach, renewed focus on financial inclusion, and concrete steps against online child sexual exploitation dominated the agenda at the FATF Plenary held in Paris from 19–21 February 2025. Under the Presidency of Elisa de Anda Madrazo of Mexico, delegates from over 200 jurisdictions endorsed targeted updates to the FATF Standards, closed out key workstreams, and opened three public consultations that will shape policy and supervision through 2025.

Why dividend arbitrage matters for AML/CFT supervision

Dividend arbitrage schemes (for example, so‑called cum‑ex and cum‑cum transactions) exploit dividend taxation and refund mechanisms to create unjustified tax refunds. Even when a scheme’s criminal classification varies across jurisdictions, its use of the financial system can generate large illicit proceeds and create material legal, operational and reputational risks for banks. That makes tax integrity — the obligation of firms to prevent involvement in tax fraud and to avoid becoming channels for laundering proceeds of tax crimes — a legitimate and important focus for both prudential and AML/CFT supervisors.

Following the EBA action plan of April 2020, EU prudential and AML/CFT guidance was updated to require supervisors to consider tax issues in governance, suitability assessments, Supervisory Review and Evaluation Process (SREP), ML/TF risk factors and risk‑based AML/CFT supervision. In 2024 the EBA carried out a targeted peer review across six Member States (Denmark, France, Germany, Ireland, the Netherlands and Spain) to assess how supervisors implemented these changes and whether their supervisory approaches are proportionate to the national ML/TF risk posed by tax crimes.

A major leap for FIUs and Europol Europe’s fight against financial crime entered a new phase yesterday, 3 February 2025, with the go‑live of the Next‑Generation FIU.net. This upgraded platform gives Financial Intelligence Units (FIUs) across the EU, plus Norway and Europol, a faster, more reliable, and more secure way to exchange and cross‑match data. In a threat landscape where criminals rapidly exploit new technologies to launder money, move illicit proceeds, and finance terrorism, the ability to share and analyse information quickly and accurately is critical.

The Financial Action Task Force (FATF) Annual Report for 2023-2024 provides a comprehensive overview of the organization’s activities, achievements, and strategic priorities during the Singapore Presidency under Mr. T. Raja Kumar.

The Projet de loi 8486 proposes a targeted but consequential revision of Article 506‑1 of the Luxembourg Criminal Code. The amendment replaces a fragmented, partly outdated catalogue of predicate offences with a clearer, more coherent provision covering money‑laundering conduct linked to a broad range of underlying crimes and serious offences. The change is presented as necessary to remove obsolete references, close interpretative gaps and align Luxembourg with international anti‑money‑laundering standards highlighted by the Financial Action Task Force (FATF).

Introduction to the EBA’s 2024 Achievements in AML/CFT

The European Banking Authority (EBA) has released its 14th AML/CFT newsletter, summarizing significant developments and regulatory updates in the fight against money laundering and terrorist financing throughout 2024. The newsletter highlights final guidelines, new regulations affecting crypto-asset service providers, supervisory improvements, and the evolving EU regulatory framework. These updates reflect the ongoing commitment to strengthen financial crime prevention across the EU.

The European Union closed 2024 by adopting a 15th sanctions package against Russia, sharpening its focus on enforcement, circumvention, and financial risk insulation for EU firms. For financial crime practitioners, the package matters less for its headline numbers and more for its operational mechanics: targeted listings that expand exposure risk, new maritime measures that intensify due diligence burdens, tighter trade controls with third-country spillovers, and defensive legal shields designed to blunt retaliatory litigation from Russia. Taken together, these measures raise the compliance baseline for banks, insurers, traders, and logistics players operating anywhere near Russian-facing flows or high-risk third-country intermediaries.

Ongoing Improvements Amid Key Challenges

The European Banking Authority (EBA) has published its latest report on the functioning of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) colleges, showing that while competent authorities continue to improve cooperation and effectiveness in 2023, significant challenges remain. AML/CFT colleges, permanent structures designed to facilitate cooperation among supervisors of cross-border financial institutions, are critical tools in fighting financial crime within the EU.

The European Banking Authority (EBA) has released the findings from its fourth and final round of reviews on how national competent authorities (NCAs) supervise banks to combat money laundering (ML) and terrorist financing (TF) risks within the EU/EEA. This comprehensive assessment covers all 40 NCAs responsible for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) supervision across 30 member states.

On November 14, 2024, the European Banking Authority (EBA) finalized two essential sets of guidelines aimed at standardizing how financial institutions and payment service providers (PSPs) comply with Union and national restrictive measures. These measures are critical in enforcing sanctions and other financial restrictions that support EU values, international peace, security, democracy, and human rights.

The guide provides a detailed framework on how to implement financial restrictive measures, also known as sanctions, in Luxembourg. It serves as a practical guide for natural and legal persons, entities, and authorities involved in applying these sanctions, which are imposed to comply with international and European Union (EU) obligations.

Money laundering (ML) poses a critical threat to financial systems worldwide, undermining economic stability and national security. The Financial Action Task Force (FATF), a global inter-governmental body, emphasizes that an in-depth understanding of ML risks is fundamental to building effective national Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) frameworks. To this end, FATF’s Recommendation 1 requires countries to identify, assess, and understand their ML risks continuously and tailor their AML measures accordingly.

The comprehensive guide provides detailed instructions and recommendations for the implementation of financial sanctions within Luxembourg’s legal framework to combat terrorism financing. This guide is intended as a practical resource for natural and legal persons, entities, and supervisory bodies involved in enforcing financial restrictive measures, also referred to as sanctions or restrictive measures.

The first Financial Action Task Force (FATF) Plenary chaired by Elisa de Anda Madrazo of Mexico closed in Paris on 25 October 2024, marking a pivotal moment for the global AML/CFT/CPF agenda. Delegates from over 200 jurisdictions and international organizations convened for three days to conclude the fourth assessment cycle, update monitoring lists, advance financial inclusion work, and set direction for the next phase of more focused, risk-based mutual evaluations.

A sharper, risk-based approach to global AML/CFT oversight The Financial Action Task Force (FATF) has announced significant changes to how it prioritizes jurisdictions for review and potential listing, aiming to concentrate scrutiny on countries that pose greater risks to the international financial system while easing pressure on least developed countries (LDCs). The reforms, unveiled on 17 October 2024, recalibrate the criteria for “active review” and adjust timelines for lower-capacity jurisdictions, with the goal of improving outcomes and reducing unintended development impacts.

Addressing Emerging Risks in Virtual IBANs and Crypto-Assets

The European Banking Authority (EBA) has recently intensified its efforts to combat money laundering and terrorist financing (ML/TF) by releasing a series of reports, guidelines, and supervisory priorities that target emerging risks in the financial sector. One of the key focuses is on “virtual IBANs” (vIBANs), a technology widely used in payment processing.

Since 2021, the Financial Action Task Force (FATF) has embarked on a significant review to address the unintended consequences arising from anti-money laundering and counter-terrorist financing (AML/CFT) measures. These consequences include the phenomena of de-risking, financial exclusion, undue restrictions on non-profit organizations (NPOs), and potential curtailment of human rights. This initiative underscores FATF’s commitment to refining its standards to balance effective risk management with inclusivity and respect for civil society.

The Financial Action Task Force (FATF) has been pivotal in shaping global policies to combat financial crimes such as money laundering (ML), terrorist financing (TF), and proliferation financing (PF). Since 2019, FATF extended its anti-money laundering and counter-terrorist financing (AML/CFT) standards to virtual assets (VAs) and virtual asset service providers (VASPs). With the rapid growth of digital currencies and decentralized finance, the FATF continues to monitor and update regulations to mitigate emerging risks.

The Financial Action Task Force (FATF) has long identified non-financial professionals such as lawyers, accountants, trust and company service providers (TCSPs), and real estate agents as critical gatekeepers in the fight against money laundering and corruption. These professionals can either unwittingly or knowingly facilitate illicit financial flows by enabling corrupt actors to launder proceeds from bribery, embezzlement, and other corrupt practices. Due to their unique access to the financial system and ability to create complex legal and corporate structures, gatekeepers hold a frontline responsibility in preventing financial crimes.

The document titled “Update of the EU Best Practices for the Effective Implementation of Restrictive Measures (Sanctions)” issued by the Council of the European Union on 3 July 2024 provides a comprehensive framework for the implementation, monitoring, and enforcement of EU sanctions. This policy paper aims to enhance the effectiveness and consistency of restrictive measures across EU Member States while ensuring compliance with applicable Union and national laws.

The “Sanctions Guidelines – update”, dated 2 July 2024 and issued by the Council of the European Union, provides an updated and consolidated set of guidelines on the implementation and evaluation of restrictive measures (sanctions) under the EU Common Foreign and Security Policy (CFSP). These guidelines are critical for ensuring the uniform application, legal clarity, and effectiveness of EU sanctions regimes.

At its recent Plenary, the Financial Action Task Force (FATF) reached a strategic milestone by approving revised criteria for prioritising countries for review under the International Cooperation Review Group (ICRG) process. The refreshed framework will apply in the next round of evaluations and is designed to sharpen the focus on risk, enhance fairness and transparency, and better account for the capacity constraints of least developed countries. This shift aims to direct attention and resources where the threats to the international financial system are most acute, while ensuring countries with limited capacity are not unduly disadvantaged.

The fight against financial crime is complex and ever-changing, requiring diverse talents and perspectives to keep pace with the evolving challenges criminals pose. Recognizing the vital role women play in society and the need to reflect this in anti-financial crime efforts, the Financial Action Task Force (FATF), under the Singapore Presidency (2022-2024), launched the Women in FATF and the Global Network (WFGN) initiative. This platform aims to promote gender diversity, empower women, and inspire the next generation of leaders in the fight against money laundering, terrorist financing, and proliferation financing.

A New Era in the Fight Against Financial Crime

In 2024, the European Union took a major step in strengthening its fight against money laundering (ML) and terrorist financing (TF) by agreeing on a comprehensive anti-money laundering and countering the financing of terrorism (AML/CFT) package. This package introduces a harmonized single AML/CFT rulebook across the EU and establishes the Anti-Money Laundering Authority (AMLA), a new dedicated body designed to oversee and enforce these rules. AMLA will focus particularly on supervising cross-border financial institutions that carry the highest ML/TF risks.

The European Union’s 14th package of sanctions against Russia marks a notable shift from broad-based embargoes toward precision tools that harden enforcement, close financial backdoors, and neutralize logistics that underpin the war economy. For compliance teams, banks, maritime operators, energy traders, and tech exporters, this package raises the bar on risk management, third‑country exposure, and supply chain assurance.

New Guidance for Crypto-Asset Service Providers to Manage ML/TF Risks

In January 2024, the European Banking Authority (EBA) extended its Guidelines on money laundering and terrorist financing (ML/TF) risk factors to include crypto-asset service providers (CASPs). Recognizing that CASPs can be exploited for financial crimes due to the rapid transfer speeds and the potential anonymity features of certain crypto products, the updated guidelines assist these providers in assessing their exposure to ML/TF risks.

In financial crime prevention, the phrase “risk-based approach” (RBA) has become a central term. It means that authorities and obliged entities should not treat every case in exactly the same way, but instead focus their limited resources where the threat is highest and where action is most effective. In practice, this is meant to replace a purely rule-based, box-ticking mindset with a more targeted method that follows the actual danger posed by money laundering (ML) and terrorist financing (TF).

The Council of Europe’s Counter-Terrorism Strategy 2023–2027 sets out a comprehensive and rights‑based blueprint for confronting the complex, shifting terrorist landscape across Europe. Building on the 2018–2022 Strategy, the new framework was developed by the Committee on Counter-Terrorism (CDCT) and approved in late 2022 to respond to notable changes:

• the decline of territorially based, centrally directed groups in the Middle East;
• the rise of “post‑organisational” terrorism driven by lone actors and small cells;
• the rapid growth of violent far‑right attacks; the persistent though varied risks posed by foreign terrorist fighters (FTFs); and
• the expanding misuse of modern technologies for recruitment, coordination, propaganda and attack execution.

The Wolfsberg Group, a leading association of global banks focused on financial crime prevention, has released a critical paper aimed at helping Financial Institutions (FIs) assess risk and demonstrate the effectiveness of their Anti-Money Laundering and Combatting the Financing of Terrorism (AML/CTF) programs. Building on prior work, this guidance centers on prioritizing national or supra-national risks and focusing on meaningful outcomes rather than mere technical compliance.

Luxembourg’s Ministry of Justice, working with the CSSF (the AML/CFT supervisor) and the CRF (the financial intelligence unit), published a vertical risk assessment focused on virtual assets (VAs) and virtual asset service providers (VASPs). The document explains why VAs matter for money-laundering and terrorist‑financing (ML/TF) risk, maps the marketplace, and provides a first structured evaluation of threats, vulnerabilities and existing mitigations. The work responds to earlier National Risk Assessments (NRAs) and to international expectations (FATF and EU) that jurisdictions identify, understand and act on VA-related risks.

The Council of Europe’s Group of States against Corruption (GRECO) assessed Luxembourg in 2017–2018 to examine how the country prevents corruption and promotes integrity among persons exercising top executive functions (PTEF) and within the Grand Ducal Police. The resulting Fifth Evaluation Round report, adopted in June 2018, finds many positives – high international perception scores, proactive press briefings after Government Council meetings, and an existing code of conduct for ministers – but emphasizes important gaps and systemic weaknesses that could undermine public trust and expose Luxembourg to subtle forms of undue influence: conflicts of interest, revolving-door risks, weak transparency on administrative documents, limited oversight and enforcement of conduct rules, and resource and structural shortfalls in internal police oversight.

On 5 May 2015 the Luxembourg government deposited draft bill No. 6810 to establish a framework for an administration that is transparent and open. The proposal requires public bodies to proactively publish administrative documents online, grants any natural or legal person a right to access administrative documents, expands the scope of accessible documents to include those held by public-law entities and entities providing public services, and establishes an independent Commission for access to documents (Commission d’accès aux documents) to review refusals. The text narrows and clarifies exceptions to disclosure, limits the right of refusal to specific, narrowly defined interests, and sets practical rules on requests, timing and redaction.