Complex rules, clearly seen.
9 June 2026, at the Alte Oper in Frankfurt am Main, under the title Building Trust, Enhancing Integrity: A New Chapter in the EU’s Fight Against Financial Crime. The Authority’s leadership, the Commissioner responsible, the chairs of the two parliamentary committees that scrutinise AMLA, the host Member State and three panels spent a day saying what the new framework is for. What follows is what they said that a firm can use, with links to the tracker items where each point is followed up.
The Chair, Bruna Szego, opened the conference the day before the thirty-fifth anniversary of the first Anti-Money Laundering Directive. A model relying only on national implementation, she said, cannot succeed against a challenge as complex and transnational as financial crime, and she put it in a borrowed line: the old model faced international tigers with domestic tamers.
She gave three reasons the moment matters. Risk is being driven by geopolitics and technology together. War and regional conflicts are fuelling radicalism and terrorism and generating large illicit flows, sanctions evasion among them. Criminals turn to crypto-assets to launder across borders, and to artificial intelligence to disguise schemes and scale up cyberattacks. Financial crime is therefore qualitatively different: not simply greater in scale, but more cross-border and harder to trace. The cost to society is large: citing Europol, she said laundering underpins most forms of organised crime operating in Europe, distorts competition in the internal market and weakens confidence in public institutions. And it is a question of strategic autonomy, a subject usually discussed in terms of defence, energy or critical technologies. Protecting the integrity of the financial system is essential to Europe’s economic sovereignty. It also matters for enforcing its sanctions and for preventing external actors from exploiting its markets.
The Authority’s work is organised around three results meant to reinforce one another: a deeper understanding of risk and technology, more consistent supervision, and better financial intelligence. Supervisory approaches still differ enough to leave room for arbitrage. Closing the gaps will require adjustments from supervisors and from the private sector. The aim is that an entity supervised in one Member State faces expectations comparable to those in another. The integration is the structural claim. For the first time supervision and financial intelligence coordination sit under one roof at Union level, so that financial intelligence informs supervision and supervisory findings flow back into the FIU pillar. She was direct about what this asks of firms: AMLA is adapting to the new risk environment, and it needs the same level of adaptation, investment and vigilance from the private sector.
On burden she made commitments the rest of the day built on. The Authority examines every instrument for opportunities to simplify, gives a reasoned justification of how proportionality has been applied, and analyses interlinked mandates together rather than one at a time. She attached a condition: simpler and more proportionate, but never at the expense of effectiveness. In her words, anti-money laundering and countering the financing of terrorism are too important for compromise, and the bar must remain high. She also said AMLA is building a central AML/CFT database, that uneven technological capacity among national authorities is itself a vulnerability, and that tools AMLA develops could in future be shared with them.
The Commissioner for Financial Services, Maria Luís Albuquerque, gave the scale in figures from others. The United Nations estimates that between 2 and 5 per cent of global GDP is laundered each year. According to Europol, 110 billion euro of it passes through the Union, and only one per cent of criminal proceeds is confiscated. She said the context has changed since the Commission proposed AMLA in 2021, with foreign actors more active in seeking to exploit and weaponise vulnerabilities in the financial system.
Her substantive argument was about the form of the rules. The past response to divergent national implementation, she said, was to make the rules more detailed and leave less room for manoeuvre, which added complexity without adding effectiveness. A consistent European approach to supervision through AMLA makes it possible to move instead towards more principle-based rulemaking and risk-based supervision. Many people hear simplification and fear deregulation, she said. But complexity, in her view, does not necessarily produce better supervision, and a simpler framework is in many cases a more effective one. Good supervision rests on risk assessment and sound judgment, and is not measured, or necessarily achieved, by a high volume of reporting.
She said the legal framework already contains the basis needed for data sharing, including with and among private sector actors subject to safeguards, which is a different position from the industry request on the second panel for binding standards. She said the international environment is affecting the ability of global bodies, the FATF included, to set high-quality and ambitious standards, and that AMLA should lead by example and support neighbouring and candidate countries. She closed on the conference’s theme: trust is not a by-product of a well-functioning financial system but one of its foundations.
ECON. Aurore Lalucq, chair of the Committee on Economic and Monetary Affairs, said AMLA matters not because Europe needs another agency but because it needs a common capacity to defend itself, against terrorism, organised crime, drug trafficking and foreign interference. Anti-money laundering measures are discussed as technical compliance and they are not, she said: they decide whether a billionaire criminal or a corrupt oligarch can buy a different version of justice from the citizen who pays tax. She gave a Europol and EU drugs agency estimate that drug trafficking is the largest criminal market in the Union at around 30 billion euro a year. Three passages were operational. If AMLA wants to be relevant it must treat crypto-assets not as a concern for tomorrow but as an immediate priority. Major global allies signalling that they will not enforce transparency over who owns and controls companies are creating blind spots; she named no jurisdiction. And by July 2027 financial intelligence units must stop operating as silos and share data automatically in standardised formats, applying the principle of collect once and use many times.
LIBE. Javier Zarzalejos, chair of the Committee on Civil Liberties, Justice and Home Affairs, framed the question his committee exists to ask: how to protect democratic societies against money laundering while remaining committed to the rule of law, fundamental rights and democratic accountability. He called the non-financial sector no longer peripheral but a central pillar. He named lawyers, accountants, auditors, notaries, tax advisers and corporate service providers as gatekeepers. He also cited a Europol estimate that 86 per cent of the most threatening criminal networks use legal business structures. He said AMLA does not replace national FIUs. His recurring condition was that stronger powers need stronger safeguards, and he said public-private partnerships are not instruments of indiscriminate surveillance.
In the tracker: item 25, item 12, item 19, item 24 and item 18.
Jeanette Schwamberger, State Secretary at the German Federal Ministry of Finance, spoke for the host Member State. She expressed Germany’s support for AMLA and called the package applying from July 2027 a game changer. She set out conditions for implementation. It succeeds only if obliged entities and national authorities can meet the requirements as simply as possible. Guidance must be precise and practical, and the risk-based approach must be applied consistently. She also warned that the standards risk overburdening small and medium-sized firms in the non-financial sector, which usually lack the compliance departments of credit institutions. She also referred to an omnibus simplification package reaching this area in the medium term.
The panel was held on International FIU Day and moderated by Executive Board member Hennie Verbeek-Kusters. It ran the length of the chain: Daniel Thelesklaf, head of the German FIU; Elżbieta Franków-Jaśkiewicz, Chair of the Egmont Group; Major General Vito Giordano of the Guardia di Finanza; European Prosecutor Gabriel Seixas; and Niamh Davenport of Banking & Payments Federation Ireland.
The panellists each spoke in favour of quality over quantity. The interesting part is what each meant by it. The German FIU now scores every report from nought to a hundred. It will give feedback on high and medium scores. It will deliberately not give feedback on low scores, so as not to push volume up. The banking side warned that a harmonised reporting template should not strip out the free text that tells the story, now that technology can read it. The European Prosecutor said that when a disclosure fails to open a case the cause is usually missing documentation rather than weak intelligence. The Egmont Chair said AMLA should preserve the lower thresholds that make FIU cooperation fast, and that informal and formal channels are used in sequence, not as alternatives. And the German FIU head called data protection the elephant in the room for joint analysis, since it handles personal data across Member States whose regimes differ.
Two views on measuring the value of reports are worth reading together. Closing the conference, the Vice-Chair said that only a very limited number of reports actively feed organised crime investigations. He attributed this to architecture rather than to any lack of will. Earlier, on the panel, the German FIU head had argued that convictions are an incomplete measure of a report’s value, because a report may work preventively or produce its effect in another country. He asked whether a hundred money mule convictions are better than one conviction of a laundering network. Do the two remarks point to different ways of measuring what a report is worth? On confiscation, he and the Commissioner both gave a figure of one per cent, each citing Europol.
Executive Board member Derville Rowland moderated. The panel included Rikke-Louise Ørum Petersen of the Executive Board and two General Board members who lead national supervisors: Grégoire Vuarlot of the ACPR and Gita Salden of De Nederlandsche Bank. Nicolas Véron of Bruegel and the Peterson Institute and group anti-money laundering officers from two large cross-border banks completed it.
Ørum Petersen said the selection for direct supervision is already under way, with data collection starting early in 2027, and that the forty entities are the foundation rather than the limit because selection repeats. Being on the list, she said, reflects systemic importance and cross-border reach and is not a sign an entity is expected to fail. Vuarlot named crypto-asset service providers, innovative payment systems and cross-border issues as where AMLA should concentrate, and argued that, given the number of entities in the non-financial sector, proportionality is a practical necessity as much as a policy choice. One bank speaker described a central group check, made before national returns were filed, that found subsidiaries classifying financial institutions differently despite a group standard. Industry asked for a published supervisory manual, anonymised peer comparisons and binding standards on data sharing. This page has not found a commitment from AMLA on any of these. Does AMLA intend to respond to these requests? Véron set out the risks that authorities of this kind face: poor prioritisation, defensive decision-making, and national silos forming inside the organisation.
In the tracker: item 11, item 20, item 24 and item 25, and in the post Forty, once.
Moderated by Executive Board member Simonas Krėpšta, with Giuseppe Lopez of Europol’s European Financial and Economic Crime Centre, Beju Shah of the BIS innovation centre in Toronto, Dr Ioana Karnstedt-Hulpuș of Utrecht University, AMLA’s Executive Director Nicolas Vasse, and representatives of a blockchain analytics firm and a digital bank.
Europol described a typology on which it has issued early warning notifications: digital hawala hubs. These are invitation-only encrypted payment applications. They pair an underground banker holding funds in one jurisdiction with one paying out cash in another. The administrators take deposits and a percentage on each transfer. It also gave the operational reason virtual IBANs matter, that they frustrate attribution of an account to a person, and described instant payments as a problem of time rather than volume.
Vasse said AMLA is meant to be a risk hub, not a data hub. It will bring together macro risk, direct supervision, national supervisory and FIU joint analysis data under one roof. It will then push risks back out across the network. AMLA is building a digital service hub open to national authorities and FIUs. He said he tells his teams he wants AI agents rather than IT systems. He said the question has shifted in the last year to sovereignty, which AMLA is working on with the Commission and the European Central Bank around a hybrid of sovereign and public cloud. The academic and BIS speakers raised the governance problem that follows: rule-based systems can be gamed, powerful models cannot always explain their outputs, and a model known to be relied on becomes a target. The testing and calibration of AMLA’s selection model are recorded on the General Board page. This page has not found a published account of how the model’s outputs will be validated or explained to the entities it classifies. Will AMLA publish one?
Vice-Chair Juan Manuel Vega Serrano closed the day with a reading of each panel and a statement of what AMLA does next. On financial intelligence he put the problem as a very limited number of suspicious activity reports actively feeding organised crime investigations. He said the cause is not a lack of will but the need for a more efficient architecture, since networks exploit the spaces between fragmented authorities. The task, in his phrase, is to turn gaps into bridges, with high-value actionable intelligence in place of administrative noise. He said further work is needed to design safe pathways for authorities and the private sector to share insights securely and legally. He described the integration of supervision and financial intelligence as making AMLA a force multiplier rather than a replacement for any national authority: supervisory findings alerting the work of the FIUs, and their analysis sharpening supervisory focus in turn.
On supervision he took the second panel’s point that regulatory convergence is not an administrative burden or a distant aspiration but an operational need. It gives supervisors a common language. It gives cross-border firms predictable legal certainty in place of costly adaptation to divergent national interpretations. He said AMLA is not waiting for 2028. Convergence is being built now, while the Level 2 and Level 3 instruments are produced, and simplification will be embedded in that work. Success will be measured by the convergence of outcomes rather than the volume of rules written. On technology he described AMLA as the first European supervisory authority built from the ground up in the era of artificial intelligence, with no legacy systems or years of digital inertia, and said the tools criminals use will empower the authorities more.
Looking ahead he set out three lines of action. The first is completing the unified legal framework, to remove the fragmentation that allows regulatory arbitrage. The second is preparing the direct supervision of a core group of financial institutions. The third is strengthening the mechanisms that put timely, actionable financial intelligence in the hands of investigators and prosecutors. Beneath them sits an analytical risk framework at two levels. A macro level maps Union-wide threats, and a micro level covers sector-specific vulnerabilities and entity-level risk assessments. He presented it as the basis for setting tomorrow’s priorities rather than cleaning up yesterday’s crises. No single European authority can meet these challenges alone, he said, and he closed by inviting the room to engage with AMLA, contribute its experience and challenge the Authority whenever necessary. The conference drew more than 360 guests in person from all twenty-seven Member States, with hundreds more online.
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