AMLA ¦ Conference Panel 2: “AMLA in Practice: Supervision and Cooperation”

AMLA ¦ Conference Panel 2: “AMLA in Practice: Supervision and Cooperation”

Why AMLA was needed

The creation of the EU Anti-Money Laundering Authority, AMLA, reflects a simple but important fact: the previous system was not delivering consistently enough. The conference panel made that point clearly. Financial crime does not stop at borders, and in a fragmented supervisory environment it can exploit differences between national regimes, expectations, data requests, and enforcement styles.

From a supervisory perspective, AMLA is meant to close those gaps. The goal is not just to create another layer of administration, but to strengthen the whole European supervisory community. A more unified framework should help create a genuine level playing field, improve the management of money laundering and terrorist financing risks, and support a common understanding of emerging threats and vulnerabilities.

That said, the panel also stressed that effectiveness takes time. Building a new authority, a shared culture, and common methods cannot happen overnight. AMLA must be developed carefully, with a focus on durability, not speed for its own sake.

Convergence must mean more than rules on paper

One of the strongest themes from the discussion was that convergence cannot be reduced to formal alignment. Rules on paper are not enough. Real convergence means common action in practice. It means a shared risk culture, a shared supervisory mindset, and common expectations about outcomes.

That idea matters because AMLA was created not simply to exist as an institution, but to improve results in the fight against money laundering. Its mission is twofold:

  1. It must strengthen the integrity of the European financial system by ensuring risks are identified and addressed consistently across the Union.
  2. It must build trust – between supervisors, financial intelligence units, member states, public and private sectors, and ultimately European citizens.

To get there, the panel identified three essential ingredients: listening, coordination, and leadership. National authorities and private institutions already hold valuable experience, and AMLA will need to learn from that rather than overwrite it. At the same time, financial crime is cross-border by nature, so coordination is not optional. Leadership is also necessary because consistency depends on identifying good practice, challenging weak approaches, and raising standards across the EU.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"AMLA is designed to turn fragmented anti-money laundering supervision into a more consistent, outcome-focused system across the EU. The panel made clear that success will depend on cooperation, shared tools, and a common risk culture, not just on new rules or a new institution.

For firms, the promise is greater clarity, less duplication, and more practical supervision that focuses on real risk. For supervisors, the challenge is to build trust, use data well, and make convergence real in day-to-day practice."

Cooperation as the core of the new model

If there was one point no one disputed, it was that cooperation is critical. In this field, cooperation is not a nice extra. It is part of the design. Supervision carried out in isolation is likely to fail, because the risks themselves are cross-border.

AMLA is expected to sit at the center of that cooperative structure. It is already building frameworks, methodologies, and shared tools, while also working on a common database. That architecture matters because it moves cooperation away from ad hoc exchanges and into a more stable system.

But structure alone is not enough. The panel repeatedly returned to the importance of behavior and culture. Supervisors must be willing to focus on the highest risks and accept that not everything can be treated with the same intensity. That requires a degree of risk appetite and a willingness to lead by example. It also requires national authorities and AMLA to operate as partners rather than as separate camps.

There was also a strong message that AMLA should not become overly defensive. If it is too cautious, too slow, or too focused on avoiding mistakes rather than making decisions, it risks shrinking its own impact. Cooperation, in other words, must be active and purposeful, not merely procedural.

What this means for firms

For cross-border firms, the promise of AMLA is significant. Large institutions currently have to navigate multiple national approaches, different interpretations, and overlapping data demands. That creates cost, complexity, and unnecessary diversion from the real task of managing financial crime risk.

A truly harmonized supervisory model would change that. Firms would benefit from a more consistent methodology, clearer expectations, and a single point of contact in direct supervision. That would make it easier to focus on substance rather than on technical divergence. It would also support better internal control design, more efficient risk management, and less time spent reconciling contradictory local approaches.

The panel also made clear that firms are not passive bystanders in this process. Their role in consultations, feedback, and practical cooperation is important. They can help shape workable rules, especially where operational reality matters. In that sense, the development of AMLA is not only a supervisory project. It is a shared effort across the public and private sectors.

Direct supervision will set the benchmark

A great deal of attention is now focused on the direct supervision role of the AMLA. Initially, the authority is expected to supervise up to 40 groups and other significant entities, with the possibility of supervising more in the future. That process is already underway, and the panel stressed that this is not a distant future project. It is happening now.

The direct supervision model is intended to be simpler, stronger, and more consistent. It will rely on joint supervisory teams made up of AMLA staff and national supervisors. For the supervised entity, the hope is that this creates a single entry point and removes the burden of moving between multiple national frameworks.

Entities will be chosen based on risk. Systemic importance and cross-border reach are important factors, and being selected does not indicate weakness. It reflects the institution’s footprint and risk profile. Equally important is the expectation that direct supervision will create a practical benchmark for the rest of the market. It is not only about the first firms selected. It is also about demonstrating what effective supervision looks like in practice.

Data will drive the new approach

Another strong theme was the central role of data. Risk-based supervision depends on high-quality data, and AMLA’s model will rely on a common database and shared tools. The principle is simple: collect once, use many times.

That approach should help reduce duplication and improve consistency. It should also support risk assessment, peer comparison, and better decision-making. Several speakers stressed that data quality is not just a technical issue. It is foundational. If the data is poor, the resulting supervision and risk analysis will also be poor.

For firms, the benefit of better data use could extend beyond compliance. If handled well, it could support peer benchmarking and clearer feedback on where an institution stands relative to others. That kind of intelligence can help firms refine their own risk appetite and improve internal models, including customer risk profiling, transaction monitoring, and sanctions screening.

Success will depend on simplicity and leadership

The closing point of the discussion was that AMLA must keep things simple and real. Complex systems can become less effective if they lose sight of purpose. The authority will need to produce enough guidance to make its expectations clear, but not so much complexity that it creates confusion or delay.

Success will also require international leadership. The panel noted that Europe can no longer simply look to others for the standard. AMLA will be expected to help shape best practice globally, particularly on issues such as common data standards and legal entity identifiers. That raises the bar considerably, but it also gives the EU an opportunity to define a more coherent and modern approach.

In the end, the panel’s message was pragmatic and optimistic. AMLA will only succeed if it builds trust, works closely with national supervisors and firms, uses data well, and stays focused on outcomes. If it does that, it can make the European anti-money laundering framework stronger, more coherent, and more effective. If it does not, the whole system risks losing time and credibility.

The challenge is substantial. So is the opportunity.

Talk copyright holder(s): Anti-Money Laundering Authority (AMLA)
The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
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Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.