AMLA General Board

What happens to an open case when your supervisor changes

The Board approved the implementing standard under Article 15(3) of the AMLA Regulation, which sets the arrangements for cooperation between AMLA and financial supervisors in direct supervision, and cleared it for the Commission. The amendments after consultation were limited: refinements to the selection process drawn from the data collection for calibrating the risk model, and an exemption from certain data collection requirements where an obliged entity is clearly not eligible.

The argument was about something the standard does not solve. Several members raised what happens to supervisory and enforcement procedures already under way when competence over a firm transfers from the national authority to AMLA. Under the framework as it stands, a national supervisor may be unable to continue proceedings once it has lost competence. Members said the absence of a clear legal mechanism for those cases creates legal uncertainty and operational difficulty, and pointed to how long some administrative procedures take.

AMLA’s answer was that the Commission had taken the view that Level 2 measures cannot alter the allocation of competences set at Level 1. Alternatives had been explored in drafting and none was thought compatible with the framework. What is left is practical rather than legal: encourage proceedings to be completed during the transition, and handle whatever remains through bilateral cooperation between AMLA and the national authority. Several members accepted that this was not ideal and was the best available. The Commission added that its Legal Service would assess the draft after formal submission and that it would not be right to prejudge the outcome.

The non-financial methodology goes out, with two members against

The draft risk assessment methodology for the non-financial sector, under Article 40(2) of the Directive, was put up for consultation. The financial-sector methodology had gone to the Commission in December 2025; this one was presented as deliberately simple and as a first step, reflecting how varied the sector is, how differently developed its entities are, that many are newly covered and that most are small.

Its design is worth setting out, because a firm in the sector will be measured by it. A limited set of basic risk indicators and data points tailored to each sub-sector. A residual-risk model that places greater emphasis on inherent risk than on the quality of controls. Indicators relating to ownership structures. A simplified regime for smaller entities. A risk-based approach to supervisory assessment and reporting. It is tied to the registration requirements in Article 4 of the Directive, and it is to be implemented in phases.

Members welcomed the work and raised substantial concerns. Many doubted that entity-level risk assessment is operationally feasible across populations that large, and raised the data collection burden, the availability and quality of the data, and supervisory capacity. Several argued for more proportionality through broader use of simplified methodologies, population-based assessment, sampling, and longer transitional arrangements. The consultation timeline was questioned. Two members opposed proceeding and a third recorded reservations.

The Commission accepted the operational difficulty while pointing out that much of it comes from Level 1, and supported launching the consultation to gather evidence and explore alternatives that stay within the legislative framework. The Chair proceeded, with the timeline to be revisited and specific questions added on alternative approaches that could achieve the same objectives proportionately.

Targeted financial sanctions get a date

AMLA set out how it intends to discharge its sanctions-related mandates. Its starting point is that the new framework builds the mitigation of risks from non-implementation and evasion of targeted financial sanctions into several core processes: risk assessments, customer due diligence and ongoing monitoring. The strategy is to keep the distinction between the Union’s restrictive measures regime and the anti-money laundering supervisory framework, address the requirements through existing mandates, and add a dedicated set of guidelines.

Members supported it and raised three things. Consistency with existing frameworks, the EBA’s in particular, and no duplication or conflict. Clarity for the non-financial sector as well as the financial one. And a doubt, from some, about whether a standalone set of guidelines is needed at all rather than folding the sanctions elements into broader instruments. Several asked that the approach stay principles-based, given how fast the sanctions environment moves, and questioned what AMLA’s supervisory role here will actually be and whether national sanctions authorities should be involved.

The conclusions are unusually specific. A dedicated task force under both internal committees. High-level expectations on sanctions written into upcoming instruments, as has already been done in the drafts prepared so far. A comprehensive set of guidelines on targeted financial sanctions by the second quarter of 2027. Coordination with the European Supervisory Authorities, the EBA in particular, and with the European Central Bank. And investigation of how to bring external national authorities, ministries of finance among them, into the task force without breaching confidentiality.

The base amount, and the question of the final amount

The Board approved the final regulatory technical standard on enforcement, under Article 53(10) of the Directive, for transmission to the Commission, with no objections raised. It was published a week later.

The discussion was about the guidelines that sit beside it. The standard provides a methodology for arriving at the base amount of a pecuniary sanction, and stops there: it does not address how the final amount is reached. AMLA asked whether it should develop common principles for that final step, arguing that sanctioning practices and sanction levels differ significantly between Member States, that this produces inconsistent outcomes, and that it creates opportunities for regulatory arbitrage.

Most members had reservations about doing so at this stage. Implement the standard and the base-amount guidelines first and see whether they work, they said; sanctioning frameworks are bound up with national legal systems and administrative traditions, and competent authorities need enough flexibility. A smaller group supported AMLA, on the view that common principles could close remaining divergences while leaving national discretion. The Chair concluded that work on the base-amount guidelines continues without extending their scope, to be reassessed later in the light of implementation experience and how much convergence is actually achieved.

The database, the task forces, and the self-regulatory bodies

On the central database, AMLA reported further preparatory work to keep the future system proportionate, efficient and aligned with what the Board had already endorsed, with a consultation package due to come to the Board in September. Members pressed the same point: proportionate, risk-based, limited to what AMLA actually needs for its legal tasks, no unnecessary reporting burden and no duplication. AMLA said the design seeks to avoid duplicating other reporting frameworks and to reduce ad hoc information requests by structuring them.

On mandates, an additional task force was established for internal policies and procedures under Article 9 of the Regulation, and several draft technical standards were expected at the September meeting. AMLA named four cross-cutting workstreams: legal privilege, targeted financial sanctions, simplification and implementation support.

The substantial argument was about self-regulatory bodies. AMLA proposed ad hoc participation, dedicated consultation formats and structured information sharing, within the confidentiality rules. Members supported more engagement and insisted on the boundary: the distinction between supervisory authorities and self-regulatory bodies has to be preserved inside AMLA’s governance. They accepted ad hoc participation and targeted consultation, valued the expertise where it bears on the sectors those bodies supervise, and asked how confidentiality would work in practice when documents are shared. AMLA confirmed there is no permanent seat for self-regulatory bodies on the internal committees, that involvement is limited to matters within their expertise, and that document sharing carries confidentiality safeguards.

Calibration, and a question from the Commission’s lawyers

Two updates on the risk assessment methodologies. First, after the draft standard went to the Commission in December 2025, the Commission’s Legal Service asked for a number of clarifications to make the methodology better understood, and AMLA is working through them. The objective is still to finalise it before the end of 2026, and the Board will discuss again once the adjustments are defined.

Second, the testing and calibration exercise. A common sample has been built so that the methodology under Article 12(7) of the AMLA Regulation and the one under Article 40(2) of the Directive stay consistent with each other. National authorities are to be involved in the discussions on risk indicators, thresholds and methodological adjustments. Members asked for early engagement on methodological choices and threshold-setting and for information on how the sample was composed and what it produced, and raised the identification of eligible entities and the treatment of cross-border institutions. EIOPA, as observer, said its earlier technical comments had been taken into account. AMLA confirmed that bilateral discussions complement the governance structures rather than replacing them.

The housekeeping

The agenda was approved as tabled, no conflicts of interest were declared and there was no other business. The annex lists six written procedures concluded in this composition up to 30 June 2026. Among them are the consultation paper on guidelines under Article 26(5) of the Regulation and approval of the terms of reference for the task force on Article 9(4). The draft AMLA annual report for 2025 was circulated for comments.

All twenty-seven Member States attended, with Iceland, Liechtenstein and Norway as observer states. The observer institutions were the European Central Bank and EIOPA, with the Commission.

Legal privilege, and a board that does not agree

The most consequential item in any of these summaries so far, and it ended without a position. After the Chair’s introduction, an Executive Board member set the limits: the purpose was to agree a direction rather than a text, the subject is close to fundamental rights, and AMLA cannot authoritatively interpret Level 1 legislation.

AMLA’s staff then set out an analysis. Legal privilege is protected under Union law and the European Convention on Human Rights, subject to restrictions that are necessary and proportionate. It applies to the specific categories of information defined in the Anti-Money Laundering Regulation. And, in AMLA’s understanding, it should not be treated as a general exemption from anti-money laundering obligations, customer due diligence, the reporting of suspicions and information-sharing requirements included.

A number of Members expressed significant reservations about that analysis. Their argument is that privilege derives primarily from fundamental rights protected by the Charter and from longstanding national legal traditions, so its scope may be broader than AMLA allows. They urged caution, questioned whether any public statement was appropriate or timely, and said further technical discussion should happen in AMLA’s committees with the legal profession and self-regulatory bodies present. Some proposed a questions and answers format instead of a formal statement.

Other Members supported AMLA, on the ground that privilege read as a blanket exemption would undermine reporting, supervision and the work of the financial intelligence units. The European Commission agreed with AMLA, taking the view that the relevant provisions largely continue existing Union legislation and create no general derogation.

The Chair closed by sending the question back into the committees. The Board supported continuing the discussion in the supervisory and financial intelligence substructures before any guidance or communication is considered.

Blockchain analytics: bought from outside the Union

AMLA reported a stocktake of blockchain analytical capability across the Union, built on a survey of supervisors, financial intelligence units and law enforcement and on consultations with European stakeholders. It found three problems: dependence on a small number of providers, predominantly outside the Union; tools not well suited to what public authorities need; and wide differences in capability between Member States and between types of authority. Use is widespread among financial intelligence units and law enforcement and more limited among supervisors. The further difficulties named were expertise, training, interoperability, cost, data sovereignty and strategic dependence.

AMLA proposed something modest: knowledge sharing and training, monitoring progress, and exploring longer-term strategic solutions. Several Members wanted more, asking for an operationally focused roadmap and for consideration of a European blockchain analytics solution, along with best-practice exchange, interoperability, coordinated procurement, and mechanisms to improve access to wallet attribution information. The European Central Bank described its own use of private-sector tools as useful but limited on transparency and explainability, and said it was exploring European alternatives.

AMLA’s answer was candid. Building independent European capability would need resources and expertise the Authority does not have. The Chair asked staff to refine the approach in the light of the comments while keeping in mind the need to be realistic.

The reporting format goes out, with a phase before the phasing

The Board supported launching the public consultation on the implementing standard under Article 69(3), the format in which suspicions and transaction records are reported. It opened the following day. This is the instrument the Board steered in April towards a minimum mandatory core, and the draft presented here carries common templates and a phased implementation approach.

What is new is the assessment phase. Members stressed its importance, along with clear governance and strong involvement of the financial intelligence units in defining a common data set that is actually useful. They asked for the balance between harmonisation and operational feasibility to be kept, and raised the significant information technology investment the change would demand of the units themselves. They asked for legal certainty and enough time to implement, and for meaningful engagement with obliged entities during the consultation, smaller ones included. The Commission supported the approach and encouraged a timely launch.

Partnerships: guidance that arrives after the rule

Two things came together under this item. A working group led by two national competent authorities, set up after the February 2026 Board meeting and observed by AMLA and the Commission, reported on its work on Article 75. It split into two subgroups. A legal and regulatory subgroup worked on the scope and interpretation of the article, including what strictly necessary means. An operational subgroup worked on the verification process, timelines, notifications, amendments to partnerships and cooperation between authorities. An expert advisory group of financial intelligence units and non-financial sector supervisors worked alongside both. A drafting workshop was set for July and final proposals were to reach AMLA by the end of August 2026, to form a key basis for the guidelines.

AMLA then presented its proposal to write those guidelines jointly with the European Data Protection Board: a joint drafting team, a stakeholder consultation, and a governance structure involving both supervisory authorities and financial intelligence units, with governance set up over the summer and drafting beginning in September 2026.

Members welcomed it and then objected to the timing. The adoption date envisaged would fall after Article 75 has already started to apply. They encouraged AMLA to find a way to accelerate, and asked for consistency with related work at the EBA and the FATF. AMLA said effective guidance here requires close cooperation with the Data Protection Board, acknowledged the concern and said it would explore expediting the work. The conclusion records three undertakings, one of which is unusually concrete: AMLA would remove the December 2027 deadline from the joint press release so as to leave room for an accelerated process.

A cooperation strategy, with a sanctions guideline inside it

AMLA set out a strategy in three parts. Cross-border supervisory cooperation, through the home and host instruments and the functioning of the AML/CFT colleges. Inter-authority cooperation, phased, beginning with guidelines on cooperation between AML/CFT supervisors, financial intelligence units, law enforcement and tax authorities, then extending to other authorities, then building procedures so that authorities with no anti-money laundering remit still take money laundering and terrorist financing risk into account in their own work. And third, the risks attached to the non-implementation and the evasion of targeted financial sanctions, including dedicated AMLA guidelines to give obliged entities clarity.

The work runs through a Task Force on Cooperation with Member State representatives and observers from the EBA and the European Central Bank. One Member asked that the timeline be aligned with the application of the package and for detail on milestones and deliverables so the Board can monitor progress. AMLA said the Task Force was working on sequencing, that the legislative deadlines give a degree of flexibility, and that it intends to follow the roadmap and report back.

One set of risk factor guidelines, and a new forum

On the risk factor guidelines, AMLA confirmed the structure. It is developing a single set of common Risk Factor Guidelines covering seven legislative mandates. A dedicated workstream handles the mandate under Article 69(5), involving financial intelligence unit representatives and reporting to the FIU Standing Committee. The rest are developed by a Risk Factors Task Force under the Internal Committee on Private Sector Standards. Both committees review the whole set before it is finalised. A Member pressed on keeping the framework clearly risk-based, consistent with national and international risk assessments, and free of unnecessary complexity for obliged entities. AMLA answered that the guidelines are meant to give indicative guidance rather than an exhaustive catalogue of risks, and are to be read alongside existing requirements and national risk assessments.

The Board also supported establishing a Forum on Risks and Technology, a platform serving both compositions for discussion of money laundering and terrorist financing risk and of technological innovation, with no decision-making powers. Members asked that it not duplicate existing structures and raised the practical question of who attends, since risk analysis and technology expertise often sit in different parts of a national authority. The Central Bank and the Commission supported it. Rules of procedure are to come, with a view to launching it by the end of 2026.

Separately, the Board took note of AMLA’s 2026 organisational structure, which the Chair said is not final and will keep changing, particularly as direct supervision is prepared and begins.

Cases, and the housekeeping

The standing item on national cases ran as a series of presentations rather than the single case of April. They covered supervisory findings on weaknesses in customer due diligence and transaction monitoring frameworks and the enforcement that followed, technology supporting supervision including case management tools, and emerging risks attached to new payment mechanisms, where the difficulties named were identifying beneficial owners, tracing transactions, sharing information and cooperating across borders. The summary gives no jurisdiction, no institution and no figures for any of it.

Any other business was a confidential session. It was held at EIOPA’s premises in Frankfurt over two days. On attendance, all twenty-seven Member States were present and only Czechia and Finland sent a supervisor without a financial intelligence unit, against five in April. All three observer states sent both. The observer institutions were the European Central Bank, EIOPA, ESMA, Eurojust, Europol and OLAF, with the Commission attending.

Three standards approved, and the gap built into them

The Board approved the final drafts of the three implementing standards it had sent out to consultation on 30 April, clearing them for submission to the Commission. No objections and no abstentions. They were published three days later.

What this meeting adds is the phasing, which was not visible before. On the standard for exchanges between financial intelligence units, certain requirements apply from 2027 and the mandatory use of machine-readable fields only from 2028. On the two standards for reporting to the European Public Prosecutor’s Office, the reporting obligations and the standardised templates apply from 10 July 2027, and mandatory machine-readable reporting from 10 July 2028. AMLA presented the delay as time for technical adaptation and interoperability.

Three members spoke. One welcomed the new provisions on supplementary exchanges. Two raised concerns about the phasing, saying the period before full interoperability could mean additional manual work and operational burden for the units. One of those asked that implementation deadlines take account of whether the necessary technical specifications are actually available, and pressed for continued work towards greater use of structured data fields. The Commission supported approval while underlining that existing obligations still have to be complied with during the transitional period.

The Standing Committee now exists, and AMLA co-chairs it

At the eighth meeting two months earlier, two things about this committee were open: how wide its mandate should be, and whether a member of AMLA’s Executive Board could act as co-chair. Both are now settled, and they are settled the way the Commission said they could be.

The rules of procedure were adopted by written procedure on 15 June 2026, the committee was formally established, and an AMLA Executive Board member was designated as one of its co-chairs. A call for nominations followed for the nine member seats and for the financial intelligence co-chair.

The election used a staggered mandate so the committee does not turn over all at once: five seats for three years, four for two. Seven candidates stood for the three-year seats and two for the two-year seats. After the first round four candidates remained for the four two-year seats, so the Chair proposed appointing them without a further ballot and no one objected. Both elections were by secret ballot. The financial intelligence co-chair was elected for two years.

Priority areas for joint analysis, approved and unpublished

Article 40(2) of the AMLA Regulation requires the Board to establish a list of priority areas for joint analysis, and it approved one. The list was built from consultations with the units, contributions from EU bodies and agencies, external reports and AMLA’s own assessments, and it feeds both the future case selection framework and AMLA’s own joint and strategic analysis. It is meant to be dynamic, is to run until December 2027, and a revised list is to be developed during 2027.

The public summary does not set out the priority areas. One of them is visible only because a member proposed a change to it: cross-border money laundering through the banking sector, which is now to include third-party payments. The Chair agreed to the adjustment and the list was approved subject to it.

Members asked that future prioritisation stay risk-based and become more informed by operational experience and data, observed that the areas vary in how granular they are, and suggested later versions reflect Union-wide priorities and emerging threats more squarely. Several pressed to reach the operational phase quickly, starting with practical, well-defined topics to build experience and show the framework works. AMLA confirmed the launch of joint analysis remains on track for the fourth quarter of 2026.

A second cooperation channel, alongside joint analysis

AMLA proposed the FIUnion Hub, a secure environment for both operational and non-operational cooperation between units, intended to surface best practices and shared operational problems and to provide logistical and administrative support. It stays financial intelligence led, with AMLA coordinating and contributing expertise.

Members supported it and asked for its scope and its relationship with the joint analysis framework to be defined clearly. AMLA answered that the Hub complements joint analysis rather than replacing it, can carry cooperation in cases where a joint analysis is not necessary or not feasible, and can serve as a forum for broader strategic discussion. It also confirmed that taking part in the Hub is not a precondition for taking part in joint analysis. The proposal is to be refined and put to the Board for approval by written procedure.

Case C-222/25, and what has happened since

The case raised from the floor on 30 April was back on the agenda, named, with a member reporting on the oral hearing. He thanked the Member States that took part and AMLA, the Chair and the Member States for the coordination beforehand, and said the preparatory exchanges had produced a largely aligned position among the participating countries. The Court, in his account, showed a strong understanding of what financial intelligence units do and of how international cooperation between them works. Much of the hearing turned on the relationship between the Law Enforcement Directive and the General Data Protection Regulation.

The point he reported as common ground is the one to hold: whichever framework is found to apply, there appeared to be broad agreement that units need safeguards protecting sensitive information from disclosure to the data subject. The open question discussed was whether the safeguards available under the General Data Protection Regulation could give protection comparable to the Law Enforcement Directive. The Commission asked that conclusions wait for the Advocate General’s Opinion, expected in October 2026, and the Board agreed to return to the matter then.

It has since been delivered. On 8 October 2026 Advocate General Laila Medina gave her Opinion in Case C-222/25, Rahapesu Andmebüroo, on a reference from the Estonian Supreme Court concerning the Estonian financial intelligence unit. According to the Court’s press release, she considers that the Law Enforcement Directive applies to the processing of personal data by financial intelligence units in preventing, detecting and combating money laundering and terrorist financing. In her view such a unit is a competent authority processing data for criminal-law purposes, and this does not depend on how the unit is organised. On access, she accepts that a data subject’s access may be restricted, and that a total prohibition may be compatible with the duty of confidentiality. Any restriction needs a legal basis with clear and precise rules. It must be proportionate in scope and duration, carry minimum safeguards against abuse, and allow the supervisory authority and the courts effective control. Where a refusal is given without reasons because disclosure would endanger the public interest, the unit must tell the data subject that the rights can be exercised indirectly through the supervisory authority, which should be able to discuss the file confidentially with the unit. On the Estonian framework she indicates it does not appear to set out clear conditions for restricting access, leaving that to the national court.

An Opinion does not bind the Court. Judgment will follow and no date has been given.

goAML, and a shared dependency

Under any other business, a member raised the goAML platform, developed by the United Nations Office on Drugs and Crime, which a number of Union financial intelligence units rely on. The point was that the coming Union-wide requirements may need new functionality and new templates inside that system, and that interested units could approach the Office jointly rather than separately, so that common features get built and future regulatory requirements are actually supported.

Several members welcomed it, noting how many units depend on the platform and that a coordinated request from a larger group of users would get more visibility and higher priority, and pointing to the existing international and regional goAML user communities. Members stressed engaging early enough to support the implementation of future AMLA instruments and harmonised reporting, and suggested AMLA and the Commission could strengthen the dialogue. Both said they were willing to help.

The housekeeping, and fourteen written procedures

The agenda was adopted without amendment and no conflicts of interest were declared. The annex lists fourteen written procedures concluded in this composition up to 30 June 2026, and they are more revealing than the meeting in places. Seven are approvals of national delegates to AMLA, for Lithuania, Malta, Finland, Ireland, Greece, Hungary and Denmark, which is the financial intelligence pillar being staffed one Member State at a time. The rules of procedure of the Standing Committee and the call for nominations to it both went through this way. So did the launch of the public consultation on the regulatory standard under Article 31(3), and a call for nominations to an informal expert group on partnerships for information sharing. The draft AMLA annual report for 2025 was circulated for comments.

On attendance, twenty-five of the twenty-seven Member States were present, Bulgaria and Finland absent, with Iceland, Liechtenstein and Norway as observer states and Europol, Eurojust and OLAF as observer institutions alongside the Commission.

Joint analyses: the methodology is approved

This was the main decision of the day. The Board approved the Joint Analyses Methodology, which sets a common framework for how financial intelligence units select, prioritise and conduct joint analyses at Union level. It had been built on earlier technical work in the FIU platform and on consultation with Board members, and AMLA presented it as practical and adjustable rather than final.

Three features were singled out. The General Board is to be told more before each joint analysis is launched, which is a transparency obligation on AMLA towards the Member States rather than towards anyone outside. The Standing Committee is given a supporting role, which matters because that committee does not yet formally exist. And transitional arrangements exclude third country participation during the initial phase.

Members asked how third country units would be treated, what further guidance would follow, and how data protection requirements would be handled in implementation. AMLA staff confirmed that third country units will not take part during the minimum viable product phase, that practical guidance will follow, and that exchanges with data protection authorities were still running. The methodology can be reviewed in the light of operational experience.

Three reporting formats go out to consultation on one day

The Board agreed to launch public consultations on three implementing technical standards, taken as separate agenda items and approved without objection. They are the three later finalised and submitted to the Commission on 3 July 2026.

The format for exchanges between financial intelligence units, under Article 31(2) of the Directive. Harmonised templates for each type of exchange, standardised consent mechanisms, and alignment with related standards, all running through FIU.net. Members supported it and raised the practical problem: keeping data fields consistent across mandates, and the work needed to make national systems interoperable. AMLA said that work was running with the FIU.net developers.

The format for financial intelligence units reporting to the European Public Prosecutor’s Office, under Article 81(1) of the Regulation. A common template, machine-readable, with restrictions on use flagged in the report itself, and neutral as to the channel used. Members asked about the scope of the permitted use of information by the Prosecutor’s Office, and about realistic implementation timelines and technical specifications clear enough for national systems to be adapted.

The format for AMLA reporting to the same office, under Article 41(2) of the AMLA Regulation, which is how the results of joint analyses reach it. The template deliberately mirrors the one for the units. FIU.net is envisaged if the Prosecutor’s Office connects to it, with other secure channels available meanwhile. AMLA must flag any restriction on the use of what it sends, without that creating a new legal basis for restricting it. No Board member asked for the floor on this item.

When a report concerns another Member State

The draft regulatory standard under Article 31(3) of the Directive came as a state of play. It decides when a suspicious transaction report concerns another Member State and so has to be passed on.

The structure has two routes. For a cross-border report, where the report itself travels, the criteria are objective and tied to where the customer is. For a cross-border dissemination, where information rather than the report travels, the criteria are deliberately more restrictive, to keep the sharing proportionate and to avoid moving personal data without need. Disseminations are tiered: at the first stage only a limited set of key information goes across, the receiving authority judges relevance for itself, and it asks for more if it wants it. The draft also deals with cases where a report and a dissemination have to go at the same time.

One Board member raised the practical use of matching tools in cross-border analysis. AMLA answered that the draft requires a full match for certain selection criteria, and acknowledged that the point needs further thought within the mandate.

The Standing Committee, and who may chair it

The committee that supports the Board in this composition is still being set up. A working group has drafted its rules of procedure and agreement has been reached on most of them. Two points remain open: how wide its mandate should be, and whether a member of AMLA’s Executive Board may act as co-chair.

Members pressed for it to be established quickly, and several supported a package: a broader mandate letting it support the Board across its tasks, combined with an Executive Board member co-chairing, while the committee stays advisory. The Commission representative said that as a policy matter an Executive Board member’s involvement would not be incompatible with the Regulation if the Member States supported it, while noting that the scope of the mandate might need further legal clarification.

Three workstreams, and who is not taking part

The joint analyses minimum viable product. The minimum operational, technical and security conditions needed before joint analyses can run at all. AMLA reported progress on internal workflows, secure communication and collaboration tools, and mitigation of information security and data protection risk. The approach prioritises security, data protection compliance and essential functionality, with more to follow later.

The 2026 peer review pilot. Described as a learning and capacity building phase for the future framework rather than as a real review. A team of AMLA staff and nominated experts has been formed and prepared through a workshop; next come a questionnaire, analysis of the answers and drafting. The Board noted that participation is voluntary and that some units had opted out, on grounds of resource constraints or of evaluations recently had or shortly due.

The FIU.net transfer. Both operational responsibility and technical ownership of FIU.net move from the European Commission to AMLA. AMLA reported on governance, stakeholders and the aim of uninterrupted service, data security and continuity, with milestones ahead on hosting, governance arrangements and operational handover.

A pending case that could reshape what the units may do

Under any other business, a Board member drew attention to a case pending before the Court of Justice of the European Union on which data protection framework governs the activities of financial intelligence units: the General Data Protection Regulation or the Law Enforcement Directive. This page identifies it as Case C-222/25, referred by the Estonian Supreme Court.

The member said the outcome could have significant implications for how units operate, naming information processing, data retention, and cooperation with law enforcement and with international partners. A hearing was said to be scheduled in the near future, and the member invited other Member States to consider a coordinated approach, including taking part in the proceedings or aligning their arguments, to protect the effectiveness of the framework. An ad hoc exchange among Board members was proposed.

Several members intervened to say the question mattered to all units, naming professional secrecy, operational autonomy and information exchange. Some described their own national experience with access requests and the relevance of indirect access mechanisms and safeguards. The Chair confirmed that AMLA staff would support an ad hoc exchange within AMLA’s mandate, and would liaise with interested members to organise it ahead of the hearing.

The housekeeping, and what the Board does out of session

The agenda was adopted unchanged and the minutes of the seventh meeting had been approved beforehand by written procedure. No conflicts of interest were declared. The participant list records twenty-six of the twenty-seven Member States, Bulgaria being the one absent, with Iceland, Liechtenstein and Norway as observer states and Europol, Eurojust and the European Commission attending. The supervisory observers present at the joint meeting the day before, the EBA, EIOPA and ESMA, are absent from this composition.

The summary carries an annex that the joint one does not: eleven written procedures concluded in this composition up to 30 April 2026. They cover draft minutes of the fifth, sixth and seventh meetings, the review of the Board’s rules of procedure, approval of the Estonian and German delegates and the status of FIU delegates at AMLA, the call for participation in the 2026 peer review, and the meeting dates. It is worth reading as a measure of how much of this Board’s business is done outside its meetings.

The reporting standard, and the steer the Board gave it

The substantial item was the draft implementing technical standards under Article 69(3) of the Anti-Money Laundering Regulation, which set the form in which obliged entities report suspicions and transaction records. It was listed for information rather than decision, and the Board nonetheless changed its direction.

AMLA staff presented the scope, the structure and the classification of data fields, and the attempt to harmonise while allowing proportionality between categories of obliged entity. The discussion turned on the balance between harmonisation and flexibility. Members supported convergence as an objective and doubted the feasibility, the cost and the operational impact of reaching it quickly or completely. Many argued for a gradual approach: a minimum mandatory core data set, optional fields beyond it, and a longer-term roadmap towards the rest.

Two limits were pressed. The standard should not constrain the analytical autonomy of financial intelligence units or their ability to ask for more on the basis of national risk. And it should not load smaller entities and non-financial entities to the point where reporting quality suffers, which is the argument that the burden defeats the purpose.

AMLA staff confirmed that the preference for a minimum core and a phased approach would be fully reflected in the drafting and consultation work that followed.

An enforcement case, presented to the Board

The Board had already agreed that national authorities would present recent supervisory cases on a regular basis, to support convergence and mutual learning. This was the first under that arrangement, and the Chair confirmed at the end that such exchanges would remain a regular feature.

The case concerned a medium-sized banking group whose business was largely corporate lending and financing. Neither the group nor the Member State is identified in the published summary. The review was opened because national risk assessments had identified elevated money laundering risk attached to the misuse of legal persons and to certain financing products. The firm was examined for a risk the country had already named, not for anything it had itself reported.

The examination covered the business-wide risk assessment, governance arrangements, the internal AML and CFT framework, and customer due diligence on corporate customers. The deficiencies were assessed as systemic rather than isolated. Four are named: the risk-based approach had not been rebuilt after a merger; the business-wide risk assessment had not been kept up to date; the customer risk classification models were weak; and customer due diligence failed, including on identifying and verifying beneficial owners and on applying enhanced due diligence.

The supervisory response is the part worth reading twice. The institution said it had implemented extensive remedial measures during the investigation. The supervisor considered those measures insufficiently documented and not fully embedded in a coherent risk-based framework, and issued a formal supervisory remark and a significant administrative fine described as proportionate to the seriousness and the systemic nature of what it found. The decision was not appealed, and the case carried no major cross-border implications.

Members asked how customer files were selected, how remediation plans were assessed and how the sanction was calibrated. They were particularly interested in the cooperation between the supervisor, the financial intelligence unit and law enforcement during the investigation, which was noted as a useful practice. The presenter confirmed that supervisory colleges and information exchange mechanisms had been used, and that there were no incentives linked to not appealing.

EuReCA stays behind the wall

AMLA presented the key findings of the 2025 review of EuReCA, the central database of material weaknesses that supervisors report into. The Board treated the tool as valuable and the data as not yet comparable. Reporting is uneven between Member States, it arrives at different times, and supervisory practices differ, so Members cautioned against country comparisons and pressed for careful contextualisation if anything were ever published.

AMLA staff confirmed three things: the report stays internal, any future publication will rely on aggregated data only, and bilateral engagement with individual authorities will be used to improve data quality. The Chair concluded that the Board supported a cautious and incremental approach to further analytical use of the data.

Who sits at the table

The EFTA Surveillance Authority asked to be granted temporary observer status in the General Board and its substructures. Members broadly supported it. Some objected to observer participation in the financial intelligence standing committee on confidentiality grounds, and the Chair proposed to deal with that separately. The Board agreed in principle to a non-voting, time-limited status, with the decision to be finalised by written procedure once the standing committee question is clarified.

Two appointments were noted at the start of the meeting: AMLA’s new Executive Board member Hennie Verbeek-Kusters, and the new Executive Director of EIOPA, Damian Jaworski, EIOPA sitting as an observer institution.

The participant list is itself informative. It records all twenty-seven Member States, of which twenty-two were present with both their supervisor and their financial intelligence unit. Five sent the supervisor alone: France, Hungary, Portugal, Romania and Sweden. Among the EEA observer states, Liechtenstein and Norway sent both and Iceland sent its supervisor. The observer institutions were the EBA, EIOPA, ESMA, Eurojust and Europol, with the European Commission attending.

The rules of procedure, after a year of using them

AMLA presented the outcome of the one-year review of the Board’s own rules of procedure. Members supported the review and raised a list of substantive issues with it: the clarity and flexibility of the rules on single common representatives, the use and transparency of written procedures, the right of Members to put items on the agenda, meeting formats, and confidentiality.

The recurring theme was national coordination. Many Members asked for clearer rules to let them coordinate at home, particularly on sharing information within the limits of professional secrecy. Others asked for more consistency, standardisation and transparency in how procedures run. AMLA staff undertook to prepare a revised draft.

Two items from the Chair, and one from the floor

The Chair raised the growing relevance of geopolitical developments to money laundering and terrorist financing risk, and proposed a dedicated discussion in the Internal Committee on Supervision about how such risks are built into supervisory risk assessments and practice. She also told Members that AMLA’s first annual report was being prepared and that, because of statutory timelines, the Board would be consulted on it by written procedure rather than in a meeting.

The item from the floor had been flagged at the start of the meeting, under any other business, and it is the one left unresolved. Members raised coordination between the supervisory and financial intelligence functions on mandates with cross-cutting relevance, at Level 2 and Level 3, and asked specifically about the governance of mandates on indicators of suspicious activity. They wanted assurance that financial intelligence expertise is actually built into that work.

The Chair clarified that nothing prohibits mixed arrangements, acknowledged the difficulty, and said further reflection would follow. AMLA staff would consider possible improvements. No mechanism was agreed.

The housekeeping, briefly

The agenda was approved with the additional item from the floor. The minutes of the seventh joint meeting had been approved by written procedure beforehand, and the Board took note. The calendar of General Board meetings for 2027 was approved; the summary does not give the dates. One Member asked for complex documents to be circulated earlier, and observers pointed out that they had not been sent the proposed dates and asked to receive them, which AMLA staff agreed to do after approval. No conflicts of interest were declared.

Task Forces become the way the work gets done

The decision of the meeting. AMLA put forward the objectives, governance and work programmes of two internal committees, on the Functioning of the Supervisory System and on Private Sector Standards, together with a proposal to deliver most of its mandates through dedicated Task Forces. The Board approved the establishment of the Task Forces and their terms of reference, subject to a technical correction about the role of the European Commission.

Support was broad and the qualifications were many. Members asked for flexibility in who takes part, for information sharing that keeps mandate holders informed even when they are not in a given Task Force, and for summaries and conclusions to circulate before General Board meetings rather than after. They raised the sheer number of workstreams, the intensity of the meeting load, overlapping schedules, and what all of that costs a smaller authority. They asked that the work stay aligned with the strategic direction the Board has agreed and be guided by a clear risk-based approach, and that information technology and data infrastructure be considered early rather than late. AMLA answered on participation, information flows, governance safeguards and what it called the flexible application of experience requirements.

One line in the record deserves to be read against what happened later the same day. Members emphasised the need for early involvement of all relevant authorities, including appropriate consideration of financial intelligence unit expertise where relevant.

The non-financial sector, as the supervisors describe it

AMLA presented the findings of a survey of national authorities. This is a different instrument from the stakeholder survey that preceded the consultation on the risk assessment methodology: here the supervisors were describing themselves. The findings were fragmented supervisory practices, limited risk awareness, and significant capacity constraints.

The answer offered was a phased and pragmatic approach: a simplified risk assessment methodology, with targeted capacity building and engagement. Members supported it and pushed in one direction throughout, that supervision be proportionate, risk-based and sector-specific, that requirements on low-risk or very small entities stay limited, and that effort go to higher-risk sectors and entities. They asked for gradual implementation, realistic timelines and clear communication with the private sector.

AMLA gave an answer with two halves. Legal deadlines would be respected, and transitional considerations would be explored where possible. The survey report itself is for internal use.

Home and host supervisors: the consultation is launched

The Board agreed to launch the public consultation on the draft regulatory technical standards on cooperation between home and host supervisors, under Article 46(4) of the Directive. Their scope is information exchange, cooperation in supervisory inquiries, and common supervisory approaches in group supervision.

Four things were pressed. How the standards sit alongside the existing supervisory college frameworks. Whether early information-sharing requirements in an enforcement context are proportionate and legally certain. That proactive exchange should be confined to information with a significant impact on supervisory risk assessments, rather than to everything. And what an efficient approach to cooperation actually means for timeliness and for how supervisors communicate. AMLA answered on the interaction with colleges, on the legal basis for the information-sharing provisions, and said efficiency and significance were intended to be read proportionately.

The handbook, the database, and indirect supervision

An update covering three things at once: the approach to indirect supervision, the common supervisory methodology under Article 8 of the AMLA Regulation taken together with the risk-based supervision guidelines under Article 40(3) of the Directive, and the central AML/CFT database under Article 11. AMLA framed all three as reducing fragmentation and supporting consistent supervisory outcomes.

Members supported the direction and defended their own discretion. They asked for proportionality, flexibility and sector-neutrality in the tools, and said national authorities should keep appropriate discretion in planning and prioritising supervisory activity. On the database they asked about reporting formats, data infrastructure and information technology requirements, wanting early clarity, manageable implementation and lessons taken from existing European reporting systems. On the handbook they put the question directly as a balance between convergence and national supervisory judgement.

The point most worth noting came from the indirect supervision side: members said indirect supervision must get sufficient focus and resources alongside direct supervision. AMLA said the methodology and tools would be developed in phases, guided by usability and proportionality.

A closed session, a disputed record, and written procedures

Any other business was a confidential session. Of the three meetings in this round it is the only one with a closed item, and the summary records nothing about it.

On the minutes of the previous meeting, one member said their comments were not reflected in a balanced manner in the final text. The Chair said all comments had been taken into account, and nonetheless proposed a final review of the wording and, if needed, a further round of written procedure. The member is not identified and the subject of the disagreement is not given.

The annex lists seven written procedures concluded in this composition up to 29 April 2026. Two of them are substantive: the public consultation paper on the regulatory technical standards under Articles 16(4) and 17(3), on group-wide arrangements, and the consultation paper on the guidelines on the business-wide risk assessment. Both consultations were therefore authorised out of session rather than at a meeting. Why were these two consultations authorised by written procedure while the home and host consultation was discussed in the meeting? The summary does not say.

On attendance, all twenty-seven Member States took part, with Iceland and Norway as observer states. The observer institutions were the EBA, EIOPA, ESMA and the European Central Bank. This composition was the only one of the three that the European Central Bank attended.

Two million entities, and supervision described as low or moderate

AMLA put numbers on the non-financial sector. Fifteen categories of obliged entity. More than two million entities across the Union. Several hundred national supervisors. Significant disparities between them in business model, maturity, supervisory approach and capacity. Some sectors are newly subject to the obligations and others need substantial adaptation to the harmonised framework. And supervisory effectiveness across the sector was described as generally low or moderate, with divergent national practice and limited coordination at Union level.

Members did not dispute the picture. They raised the operational complexity of supervising professional bodies, the limited awareness of obligations in many of these sectors, and the need for coordinated outreach, innovative engagement, structured involvement of self-regulatory bodies and multilingual consultation so that people can actually take part. They asked for proportionality and gradual implementation while maintaining ambition and avoiding the preservation of the status quo. One Member State pushed the other way, observing that most of the non-financial sector has been subject to these obligations for a long time and urging that the Regulation be applied promptly and without undue delay.

The Chair said awareness-raising in this sector had been a main goal of her roadshows and confirmed that it remains comparatively less mature in understanding and implementing the obligations. AMLA undertook to tailor supervisory expectations where justified while keeping them robust, and to share communications material with national authorities for them to push out.

The enforcement standard, and a word the Board put into it

The draft regulatory standard on enforcement went out for consultation here, and the way it was done is instructive. AMLA had inherited the EBA’s earlier draft and its 2025 consultation, which had drawn limited input from the non-financial sector, so it proposed a targeted one-month consultation aimed at that sector, both to secure broader feedback and to mitigate procedural risks.

The standard sets indicators for classifying the gravity of a breach on a four-level scale, criteria for pecuniary sanctions and administrative measures, and a methodology for periodic penalty payments, with non-exhaustive lists preserving supervisory judgement and dedicated provisions for natural persons, senior management included.

Members asked for proportionality and flexibility for a sector this varied, including room to assess materiality and calibrate the measure. They raised possible national legal constraints on mandatory sanctions and the short window for reaching newly in-scope sectors. And then something concrete happened: following agreement by the Board, the draft was amended to clarify the policy intention of an indicator by specifying that failures in AML/CFT systems, controls or policies must be material, with the same clarification made in Article 5(3)(d).

The Board also agreed to admit the European Central Bank and ESMA as observers to the Enforcement Working Group. The plan set here was to finalise for adoption at the end-June meeting and submit to the Commission by the legal deadline of 10 July 2026, which is what happened.

Customer due diligence, and three objections about funds

The customer due diligence standard under Article 28 went out for a three-month consultation, launched on 9 February 2026. It specifies standard, simplified and enhanced due diligence: what information must be collected, the attributes required for electronic identification and other remote onboarding, the risk factors for the e-money exemptions, and what counts as a reliable source for verification. AMLA was explicit on one point: simplified due diligence cannot operate as an exemption from standard due diligence, and any reduction has to stay risk-based.

The dispute was about collective investment undertakings, where the draft kept the approach the EBA had previously consulted on. Three Board members objected to the inclusion of Article 17 and to its potential impact on the funds industry. Others defended it as a balanced compromise, on the ground that it avoids systematic look-through, preserves the fund manager’s ultimate responsibility and its ability to obtain information where risk warrants, and closes divergent national practice. AMLA said the provision harmonises conflicting interpretations of a longstanding Level 1 requirement. It ensures the ability to obtain information when needed, rather than imposing a systematic obligation. Newly inserted recital language says the frequency and extent of any request should reflect the specific risk being addressed.

Members also asked for calibrated simplified due diligence for well-defined low-risk cases such as pooled accounts and low-value retail products, and for clearer expectations on other means of remote identification. AMLA undertook to keep working on simplified measures, pooled accounts included, during the consultation.

Thresholds, and the lower ones that were not set

The standard under Article 19(9), which sets the criteria for identifying business relationships, occasional transactions and linked transactions, went out for a three-month consultation. The draft proposed no additional lower thresholds at this stage. Two members pointed to high-risk cash activities and invited AMLA to include some. Another asked that the recitals say internal policies and procedures for detecting these relationships and transactions may include identifying and verifying the customer.

The risk model’s year, and a scoping answer

AMLA set out the 2026 testing and fine-tuning exercise for the risk assessment methodologies in three phases. Preparation from December 2025 to February 2026: templates, taxonomies, data models, reporting packages and communication tools, the testing sample defined by national authorities, and interpretative questions cleared. Data collection from March to May 2026: national authorities gather from participating entities, run completeness and quality checks, and send validated datasets to AMLA. Calibration from June to October 2026: parameters calibrated, sensitivity and robustness analyses run, and results benchmarked against national risk assessments.

Members asked for timely communication, quick answers on interpretation, a proportionate burden on smaller entities, coverage of different business models and cross-border groups, confidentiality safeguards, and feedback on data quality. One asked a scoping question. AMLA confirmed that the financial holdings in scope for this exercise, for the first cycle of the selection process and for the collection of fees, are those within the AMLD5 scope. That excludes holding companies until they become obliged entities in mid-2027. Members also asked AMLA to flag early any risk to the timeline.

De-risking, thematic reviews, and who chairs the committees

On de-risking, AMLA gave a full timetable. The EBA is leading the preparatory work, gathering evidence from national authorities and running a targeted assessment of a small sample of institutions; AMLA steps up during 2026; joint technical work starts in the second quarter of 2026; public consultation is foreseen for late 2026 or early 2027; and finalisation by July 2027. AMLA cited the mandate as Article 21(4) of the Regulation. No member intervened.

On thematic reviews, AMLA confirmed that no joint thematic reviews are planned for 2026. Instead the year goes on engagement with national authorities, clearer coordination channels, earlier consolidation of what each authority plans, and a redesign of the EU survey questionnaire to improve data quality and harmonise how obliged entities are identified. Discussions on the 2027 reviews were to run by the second quarter, potential joint reviews to be identified by September 2026, and a methodology document for planning joint reviews prepared by the fourth quarter. Members asked that the survey feeding the 2027 plan be scheduled in October to fit national cycles.

The Board also elected the national co-chairs of its two internal committees by secret ballot in confidential session: a candidate from Austria for the Internal Committee on Private Sector Standards, and one from the Netherlands for the Internal Committee on the Functioning of the Supervisory System. Under any other business, the EBA announced publication of its amended Equivalence Guidelines, relevant to AML supervisors sitting in colleges.

A note on how these items are labelled

AMLA explained at this meeting why consultation items appear on the agenda as points for discussion rather than for decision. The intention is to mirror good administrative practice across the EU institutions, to confirm the Board’s support for launching a consultation and keep the drafting moving in parallel, while leaving the Board’s final decision-making power, exercised by qualified majority, intact. Comments made in the meeting are captured and reflected in later versions and in the process leading to adoption.

That is worth knowing when reading these summaries. An item marked for discussion is not a weaker item; it is a consultation being authorised with the decision reserved. The six written procedures annexed to this meeting include the setting up of the Enforcement Working Group, the adjusted rules of procedure of the internal committees, the establishment of the task force on the non-financial sector risk assessment, and the call for nominations to the internal committees. All twenty-seven Member States attended, with Iceland, Liechtenstein and Norway as observer states and the EBA, the European Central Bank and EIOPA as observer institutions.

Twenty heads of financial intelligence units ask for a European tool

The blockchain stocktake reported to the Board in June 2026 did not start with AMLA. It started here, with a letter from two Board members supported by eighteen others, proposing that a sovereign European blockchain analytics capability be explored. Twenty of twenty-seven is a weight of opinion that does not appear anywhere else in these summaries.

The Chair set out the case and the caution together: virtual-asset analysis is growing more complex and is inherently cross-border, and the authorities currently depend on commercial tools owned by third country companies. Exploring a sovereign capability is strategically important. It is also technically, financially and operationally complex, and other European authorities are likely to be looking at the same question, so the first step is to take stock of what exists and where the synergies are.

AMLA staff laid out the range: an EU-owned capability at one end, coordinated procurement or partnerships at the other, with interoperability, resources and governance to be worked through. Members raised sovereignty, cost, the technical and transparency limits of the existing tools, the risks around sensitive data, and the need to share information and avoid divergence. Several argued for a staged approach beginning with a map of current solutions and needs, for any Union approach to complement national capacity rather than replace it, and for joint procurement to be explored.

The Chair concluded that the work begins by clarifying needs, existing tools and realistic short and longer term options, before any role for AMLA is defined. The stocktake that followed reported back on 30 June 2026.

Two central banks take Article 75 in hand

The working group on information-sharing partnerships, whose output was still being awaited in July, was proposed here by the Central Bank of Ireland and De Nederlandsche Bank, ahead of the article’s application in July 2027.

Their diagnosis is the clearest statement of the problem on the record. Article 75 lets obliged entities and public authorities share information strictly for customer due diligence and the reporting of suspicions, but the drafting is high level, terms are undefined, and the position on data-protection oversight is uncertain. Harmonised guidance is therefore needed, and the verification process is the priority topic.

The design they proposed is a two-step one. A working group through the first half of 2026 chaired by the two authorities themselves, with AMLA attending as an observer, and then, in the second half of 2026, AMLA taking the chair to work up guidelines for supervisors and obliged entities alike. Members supported it, pressed for financial intelligence units to be involved and for alignment with data-protection guidance so that national approaches do not diverge, and raised timing, supervisory powers and how this interacts with national frameworks. AMLA reported on the European Data Protection Board’s own work on Article 75 and confirmed its engagement.

The reporting standard, at the very beginning

The implementing standard under Article 69(3) appears here for the first time, as a state of play. AMLA set out the legal basis, the objectives and the expected structure, and described work already running under a Technical Support Instrument project with the European Commission and the Council of Europe, whose outputs were to be the basis for drafting. An AMLA-led working group was to launch in February.

Members raised flexibility, timelines, sectoral needs, and the effect on the information technology systems of financial intelligence units, of national authorities and of the private sector.

Europol, and a case built on investment fraud

Europol presented a major cross-border case involving investment fraud schemes and the money laundering networks attached to them, used to show how structures spread across jurisdictions and the use of crypto-assets complicate both supervisory and financial intelligence work. Members asked about supervisory follow-up, the difficulties of sharing data, and how far service providers cooperate. No jurisdiction, institution or figure is given.

A question about who may see the papers

Under any other business a member asked whether the confidentiality rules in Article 8(3) of the Board’s rules of procedure allow documents to be shared internally with line ministries or other government bodies involved in the national anti-money laundering framework. The Chair acknowledged the question and said it would be taken up in the review of the rules of procedure about to be launched.

That review reported back on 29 April, and the same concern came back with it: many members asked for clearer rules to let them coordinate at home, particularly on sharing information within the limits of professional secrecy. It was still unresolved then.

The Chair also invited members to share risk insights or supervisory action arising from geopolitical developments, naming Venezuela and Iran, and told the Board that AMLA’s first conference was set for 9 June 2026. Twenty-seven Member States attended this meeting, two of them, Austria and Czechia, with their supervisor alone; EIOPA, Europol and OLAF were the observer institutions.

Peer reviews: opt-out, and published with names

The design of the peer review framework was settled here, and two features of it are worth more than the later reports of how it is going.

The call for participation runs on an opt-out model, so a unit is in unless it takes a step to get out, which was chosen deliberately to encourage broad participation. Volunteers from the units serve on the review teams alongside AMLA staff. The report follows a common template through the pilot, covering executive summary, background, scope and methodology, results, good practices, areas for improvement, follow-up measures and annexes, to be refined afterwards.

On publication, AMLA had consulted the European Commission to make sure of the legal position, and the answer is that publication focuses on the results and is generally in non-anonymised form, with scope to sanitise specific sensitive elements exceptionally to avoid operational risk. The Commission confirmed that reading from the floor. Members raised confidentiality and national security safeguards, warned that publishing sensitive material could expose units to operational or political difficulty, and questioned the opt-out model, the workload on smaller units, and the risk of duplicating international evaluations rather than complementing them.

The call for participation was to launch in mid-February. By the meeting on 30 April some units had opted out, citing resources or evaluations recently had or shortly due.

What a delegate owes AMLA, and what stays at home

Every financial intelligence unit delegates staff to AMLA, and this meeting worked through what that means. The draft decision aligns delegates with the framework for seconded national experts, and its terms are specific.

On the rights side: access to data, and where necessary, with the delegating country’s consent, to national unit data, with devices supplied by both AMLA and the home authority. On the obligations side: comply with AMLA’s functional authority, work exclusively on AMLA tasks, ensure prompt and technically feasible access to national databases, and keep confidentiality beyond the end of the secondment.

Members pushed back on the balance between AMLA’s functional authority and the continuing responsibilities of the delegating authority, on access to national data, on the scope of exclusivity, and on preserving the delegate’s link with home. They raised the practical consequences: who reimburses allowances, how national administrative rules apply, whether a delegate can be asked to attend a meeting back home, and the risk that a misunderstanding here discourages participation in joint analysis.

AMLA agreed to clarify the text. Functional authority does not sever ties with the delegating country; access to national databases always needs consent and is not a way around national procedure. It undertook to make three things explicit: that delegates are under AMLA’s functional authority when performing AMLA tasks, that database access is subject to the consent of the units and to national confidentiality rules, and that delegates might be involved in their own unit’s tasks in exceptional cases. The revised text was to go round by written procedure for opinion before the Executive Board adopted it.

Mutual assistance, not yet at scale

AMLA told the Board plainly that, given its start-up phase and limited staffing, assistance cannot yet be delivered at scale. The mechanism is meant to let AMLA and countries provide support where extra expertise, resources or coordination are needed, with a longer-term aim of harmonising practice. What it could do in 2026 was start a structured dialogue and send out a written request later in the year asking what units need, what expertise they have and on what conditions they would help.

Members raised emerging legal questions at Union level on data access and data protection, among them a concern about a preliminary ruling of the Court of Justice on a unit’s access to bank accounts. This is a different question from the one at issue in Case C-222/25, which concerns which data protection framework governs a unit and what a data subject may see. Some members asked how mission costs would be allocated, others raised international coordination subject to confidentiality, and one offered its own expertise to other units.

Working arrangements with the law enforcement bodies

AMLA reported progress on the working arrangements it must conclude with OLAF, Europol, Eurojust and the European Public Prosecutor’s Office, covering strategic information exchange and the exchange of operational data for joint analyses. Members asked about confidentiality, how the arrangements interact with national dissemination frameworks, and pressed that they must not create unintended obligations for national units. They asked to see the drafts before adoption. Revised drafts were to go to the partner organisations during March, with negotiations to follow. The arrangement with OLAF was signed on 21 October 2026.

The annex records three written procedures concluded up to 4 January 2026, one of which matters: the process for the selection, prioritisation and conduct of joint analyses, agreed out of session in 2025. That is the ancestor of the Joint Analyses Methodology the Board formally approved in April 2026. Twenty-four Member States attended this meeting, with Austria, Czechia and Malta absent and some members connected remotely because of travel disruption; Europol and OLAF were the observer institutions.

The meeting where the revised timetable was presented

This two-hour online meeting is the most consequential in this record for anyone planning against AMLA’s deadlines, and almost nothing in it is dramatic.

The Executive Director presented the plan for the mandates due to be delivered in 2026, and sorted them into three categories: some would be delivered on time, others would require limited extensions, and a small number would need more substantial adjustments. The supporting measures were earlier engagement at working group level and targeted consultation periods where appropriate. The Chair framed the objectives as timely delivery, adequate preparation time for the market, and robust, usable rules.

Members supported it. They said quality should remain the primary consideration, asked for clear prioritisation, transparency and early outreach to the non-financial sector, asked that contentious issues be brought to the Board rather than settled below it, and noted what participation in working groups costs them in resources. The European Commission expressed support and indicated readiness to cooperate on the revised timelines.

The Board then agreed that AMLA would finalise the planning annex to the Single Programming Document for 2026 to 2028 for publication and share the revised plan with the Union institutions. That annex sets the plan dates shown on the mandate deadlines page.

The next programming document, and the money

The draft Single Programming Document for 2027 to 2029 was discussed. AMLA described the transition from establishment to a more mature phase, with the selection of directly supervised entities in 2027 and the start of direct supervision in 2028 as the milestones, alongside strengthening policy, risk analysis, stakeholder engagement and technological capacity. It gave a target staffing level and said budget pressures in 2029 would need to be managed.

Members asked for more on the fee model and the expected timeline for fee collection, pressed the importance of international cooperation including with the FATF and the regional bodies, and asked for explicit reference to peer review planning, including for the non-financial sector. They underlined the need to protect investment in technology and data capability and raised concerns about what budget reductions would do to digital infrastructure. And they asked for transparent planning for the transfer of FIU.net in 2027. The Commission recalled that future budget contributions are subject to the multiannual financial framework and encouraged more detail on the FIU.net transfer.

The housekeeping

The minutes of the previous meeting were not put for adoption because a written procedure for comments was still running, with adoption planned for the meeting in early February. The annex records two written procedures, both fixing the schedule of Board meeting dates for 2026. Twenty-seven Member States attended, three of them, Austria, Denmark and Slovenia, with their supervisor alone; the observer institutions were Europol, Eurojust, the EBA and EIOPA.

The numbers that decide who gets supervised are not in the law

The Board approved both risk assessment standards for submission to the Commission: the common methodology under Article 40(2) and the selection methodology and materiality thresholds under Article 12(7). One sentence in the record changes how the whole selection exercise should be read.

AMLA told the Board that targeted clarifications had been made to support a timely start to the selection process, and that certain elements such as indicator weights and thresholds would remain outside the standards, to allow future adjustments.

The rest of the item set the year. The model would be tested during 2026 through a dedicated working group using sample data from national authorities, ahead of the first selection cycle in 2027. The Board endorsed the working group and welcomed a centralised, harmonised approach to data collection, data-quality controls and communication. AMLA undertook to request preliminary lists of potentially eligible entities on a best-effort basis, to publish taxonomy, templates and validation rules by the end of April, to clarify the centralised data collection approach ahead of September, and to bring a communication plan and interpretive materials to the next meeting.

Three mandates slip, named

Six weeks before the planning item of 19 January, the slippage already had names. AMLA reported increased activity on policy mandates and said some timelines may need adjustment. It identified three areas for a revised approach: more time to align the standard on the central AML/CFT database with the IT and data work; a dedicated project, with targeted engagement, for the non-financial sector risk assessment methodology; and reprioritising the standard on central contact points pending further assessment.

Members welcomed the focus on proportionality, pressed the needs of the non-financial sector, asked for broader participation in working groups and for clarity on timelines. AMLA said the working group structures would be reviewed, that the non-financial methodology would be tailored, and that discussions with the Commission on timelines are ongoing.

Where the case presentations started

Case presentations were introduced here as a standing item, and the first set is more specific than the summaries that followed. The Board heard enforcement action in the crypto-asset sector, a supervisory response to a large card-fraud scheme, and measures addressing systemic reporting deficiencies and outsourcing weaknesses. AMLA undertook to continue the series and to consider targeted work on the issues raised by new market participants.

Thematic reviews, and a comparability problem

AMLA reported strong engagement across sectors on thematic reviews and a difficulty underneath it: subjects and obliged entities are defined so differently between jurisdictions that the results cannot be compared. Its proposed answer was a phased one, refining common definitions, promoting consistent scoping and core question sets, identifying where alignment is possible, and assessing where Union-level coordination could support joint reviews in higher-risk areas.

Members supported concentrating on methodology and process during 2026, given planning constraints and the need for clear scopes, definitions and timelines. The Board concluded that joint reviews would be considered from 2027. That is where the position reported in February, that no joint thematic review was planned for 2026, was actually decided.

The handover, the committees, and a question about guidance

On the handover from the EBA, AMLA reported on current business operation and the planned IT migration of EuReCA, the hosting and transfer of the AML colleges platform, the receipt of documentation and the reinforcement of expertise, with joint communications due in early January.

The Board also endorsed the rules of procedure and operational arrangements for the internal committees, subject to minor drafting adjustments, and confirmed the fast-tracked launch of a working group on enforcement. Members asked for clarity on representation, participation, document circulation and scheduling, and asked that observer participation be written into the committees’ terms of reference. The Board also approved launching a six-week consultation on the implementing standard for cooperation in direct supervision under Article 15(3), with the final report planned for the second quarter of 2026; it was in fact approved on 1 July.

Under any other business members asked about private sector guidance needs and about the scope for national authorities to issue guidance of their own. AMLA stressed the importance of coordinated, consistent interpretation and said an approach to guidance was being considered. Twenty-seven Member States attended, with Liechtenstein and Norway as observer states and the EBA, the European Central Bank and EIOPA as observer institutions.

An Executive Board appointment, with one abstention

The Board heard a candidate for a seat on the Executive Board. The summary does not name the candidate. The candidate set out a professional background and priorities. These included cooperation, the use of information technology, harmonisation based on best practice and a proportionate risk-based approach. The candidate also spoke of synergies at Union level between supervision and financial intelligence. The risks the candidate identified were crypto-assets, cyber threats and sanctions evasion. Members briefly discussed alignment with the simplification agenda and practical synergies. The Board took note of the presentation.

Under the next item, the Board approved the proposal to the European Parliament on the appointment. Members expressed broad support. One abstention was recorded, based on concerns about aspects of the selection process. AMLA staff were to send the proposal to the European Parliament without delay.

The selection process came back under any other business. Several members expressed concern about it, citing “the absence of a shortlist and limited information”. They asked that future exercises preserve the Board’s role, with earlier documentation and greater involvement. At the first meeting, in March 2025, members had raised a similar point about the sequence of the selection.

Crypto-asset firms during the transition

AMLA set out a two-phase approach to anti-money laundering convergence and effectiveness during the transition to the Markets in Crypto-Assets Regulation. It covers crypto-asset service providers and issuers of e-money tokens and asset-referenced tokens.

The first phase has three parts. There are two questionnaires, one for anti-money laundering supervisors and one for financial intelligence units. There is a workshop. And there is a strategic analysis report, to be published in the second half of 2026. The report is to give a data-driven assessment across the Union, with strategic recommendations. At the October 2025 meeting, the first strategic analysis had been aimed at spring 2026.

The second phase is for the period after the transition. It consists of joint thematic reviews and, where appropriate, joint analyses. The reviews would assess the money laundering and terrorist financing exposure and the compliance of these firms. They may involve all relevant supervisors. Their scope is to be set after the questionnaires have been analysed. AMLA would also liaise with authorities planning national thematic reviews of crypto-asset service providers in 2026.

Members asked for the scope to be clarified. They asked for the Transfer of Funds Regulation and targeted financial sanctions to be included. They asked for alignment with international work on the risks of offshore service providers. On the questionnaires, they asked for redundancies to be removed and qualitative elements added. They suggested separate questionnaires where responsibilities are shared between authorities. They also proposed a regular forum on legal interpretation and supervisory cooperation. The Board noted the initiative and the next steps.

The programming document for 2027 to 2029

AMLA presented the outline of the draft Single Programming Document for 2027 to 2029. Its areas are governance, readiness for direct supervision, and coordination between supervision and financial intelligence. They also include completing the single rulebook, risk intelligence, stakeholder engagement and technology.

Members asked for a holistic mapping of Level 2 and Level 3 instruments. They asked for clear sequencing and prioritisation of data collection, in line with capacity. They asked for meaningful consultation windows, and for clear deliverables and timelines for 2027. The Board noted the direction and the planned timeline. It asked for detailed mapping, prioritisation and clear external communication. AMLA staff were to look at attaching a detailed mapping to the final document in 2026. The same draft was discussed again on 19 January 2026.

More time for some 2026 standards

An item on extension of time and phasing of technical standards development was taken for information. Members supported a flexible approach. They asked that consultations with industry remain meaningful. They also asked for clear communication, and for publication and application dates to be aligned.

The Commission outlined the process after a draft standard is submitted, and invited feasibility checks. AMLA clarified that the exercise covers the 2026 standards. Any phasing in 2026 would be limited to the standard on the risk of obliged entities. The Board noted the update and the planned approach.

AMLA staff were to finalise the dates with the Commission and propose the plan to the Board in January. The agreed timeline was then to be published. The plan was presented at the sixth meeting, on 19 January 2026.

The housekeeping

No conflicts of interest were declared. Members asked for documents to be circulated earlier and for clearer version control, to support coordination at national level. AMLA staff said documents would be sent eight working days in advance from 2026, and that versioning would improve. The agenda was approved without comments. The minutes of the fourth joint meeting were approved, the written procedure on them having drawn no substantive comments.

Under any other business, a written procedure was to be launched in January to gather targeted suggestions on the Rules of Procedure. Proposals were to come back in April. The review was reported to the Board on 29 April 2026. The 2026 calendar was adjusted, including an extraordinary online meeting in January. Members asked for early notice of the order in which the segments would run. AMLA staff said the start-up task force would cease from the following year, and members recorded their appreciation.

The summary has no annex of written procedures. All twenty-seven Member States attended. Belgium, Bulgaria, Latvia and Portugal sent their supervisor alone, and Cyprus and Slovenia their financial intelligence unit alone. Among the observer states, Iceland sent both, Liechtenstein its supervisor and Norway its financial intelligence unit. The observer institutions were the EBA, the European Central Bank, EIOPA, Eurojust and Europol, with the Commission attending.

Joint analyses are voluntary, and so is paying for them

AMLA set out how joint analyses would be launched: pilots in the second half of 2026, methods, criteria and procedures consolidated into a single document with transitional clauses for the pilot phase, and FIU.net used with incremental improvements where feasible.

Members asked about interim tooling, secure storage and hosting, and then asked for something more fundamental. They sought assurance that participation remains voluntary and that resource contributions are at the discretion of each unit. AMLA confirmed both.

What the peer reviews are actually about

The work plan names the themes, which the later summaries do not. Two successive one-year reviews with teams of AMLA staff and unit representatives: resource adequacy in 2026, and reporting quality with analytical tools in 2027, with a light overview of remaining points. A call for volunteers was to go out in January, followed by a preparatory workshop.

Members raised confidentiality and the publication of outputs, the participation of delegates, how reviewers would be selected, training, and the timing of invitations. One asked that the flexibility to revisit the 2027 theme be retained.

The Standing Committee: from an eight-week target to adoption in June

The Board approved a way forward for establishing the Standing Committee for the financial intelligence pillar under Article 58(4). A dedicated working group of AMLA staff, unit representatives and legal advisers from the European Commission would finalise a consolidated draft of the rules of procedure. The target was eight weeks, with limited flexibility. Members supported it, stressed the urgency and the need to safeguard the autonomy of the units, and asked whether the Commission’s legal service would actually be available.

The rules of procedure were adopted on 15 June 2026. In the meantime, at the meeting of 30 April 2026, two questions were still open: how wide the committee’s mandate should be, and whether an AMLA Executive Board member could co-chair it. Both were resolved in June, the second in favour of AMLA co-chairing. The nine members were elected on 30 June 2026.

FIU.net, and who owns what is in it

AMLA set out the transfer timeline to July 2027, with continuity of service as the priority, a transitional role for the Advisory Group, and post-transfer integration within AMLA in which data ownership remains with the financial intelligence units, alongside work on infrastructure, security and data protection. Members discussed the future governance model and how far the units would be involved in it, and supported the timeline.

AMLA also described an exercise to collect and map the legal frameworks, organisation and activities of the units themselves, on a dedicated platform the units enter and view. Entries are structured for comparability and aligned where possible with existing statistical collections. Delegates lead the collection and their authorities verify it. It is intended to support peer reviews and mutual assistance. Members asked about transparency, whether a unit’s consent would be needed for others to view its entry, and how access and publication would work. AMLA said the platform aims to be transparent within the community, that consent to view would be sought as good practice, and that the modalities would come back to the Board.

Where the crypto discussion was put on the agenda

Under any other business, members supported holding a joint discussion at the next meeting on crypto-asset analytics and related tooling with the relevant Union bodies. AMLA undertook to arrange it for February. That is the item at which, on 4 February 2026, a letter from two members supported by eighteen others was put to the Board proposing a sovereign European blockchain analytics capability.

The annex records four written procedures, one of which matters beyond housekeeping: the rules of procedure for mediation, put to written procedure in October 2025. Mediation and peer review are the two instruments AMLA has named for this pillar, and the mediation rules were settled out of session before either was used. Twenty-four Member States attended, with Croatia, Lithuania and Portugal absent, and the observer institutions were the EPPO, Eurojust and Europol.

The Commission clears joint analyses to start early

Several members had been asking at previous meetings whether AMLA could run joint analyses before the Directive was transposed everywhere, and the Chair put the question on this agenda for an answer. The European Commission’s representative gave the view of its Legal Service, and the answer was yes.

The directly applicable provisions of the AMLA Regulation are themselves the legal basis for exchanging the information needed to perform joint analyses, including personal data where required, consistent with the Union data protection framework. The information-sharing provision in the sixth Anti-Money Laundering Directive is not a precondition, because the AMLA Regulation is the specific legal basis for cooperation between AMLA and the financial intelligence units.

FIU.net: access now, ownership later

AMLA reported that its technical connection to FIU.net was nearing readiness and that arrangements for the eventual takeover were being prepared in the advisory forum. Members pressed for a comprehensive policy on transferring, hosting and managing the network to be developed during 2026, before AMLA takes it on in 2027. They listed what they called the trust-critical matters: data protection and retention, information technology security, interoperability across the tools the units use, and the possible use of the network to disseminate information to other Union bodies with prosecutorial or anti-fraud responsibilities.

Two things came from the Commission. An agreement with AMLA was to be signed. And requests from financial intelligence units in candidate countries to join the network would be for this Board to decide, taking the associated costs into account.

Mediation, and what the units wanted in it

The rules of procedure for mediation between financial intelligence units were presented, with their principles, steps and safeguards including confidentiality and data protection. Members asked for four changes: clarify the role of the Standing Committee, which did not yet exist; add joint analysis as a trigger for mediation; consider telling a unit that is the subject of an assessment what AMLA has concluded, and letting the units involved take part in the written procedure; and define criteria for urgency. It was recalled that whether the Standing Committee is involved at all is for the Board to decide.

The comments were to be integrated and the rules adopted by written procedure, which was launched later that month.

Peer review, at the provisional stage

The Board approved by consensus the provisional rules of procedure for the first peer reviews, built as a transitional framework on a voluntary, test-and-refine basis. Members supported it as mutual learning and the sharing of good practice, and asked for clarity on confidentiality and publication, for smaller or rotating pools of reviewers, for the review duration to be adjusted, and for follow-up to stay proportionate and flexible. AMLA said publication modalities and team composition would be settled in the work plan due in December.

A written procedure was to invite the units to propose priority themes for the first two reviews. The themes that came back, presented in December, were resource adequacy for 2026 and reporting quality with analytical tools for 2027. The opt-out model and the decision to publish results generally naming the Member State came in February 2026.

AMLA also set out the call for proposals for joint analysis priority areas, describing the obligation as drawing up an annual list, with a consolidated list to be adopted in December 2025 together with procedural guidance for the pilot. It also reported that the procedural guidance for submitting a request for mutual assistance, prepared with the subgroup, would be published on its website. Members encouraged collaboration with Egmont. They asked that any discussion of shortcomings be used solely for technical assistance, and cautioned against unintended disclosure of proprietary information through the tools.

The housekeeping

Six written procedures are annexed, three of them designations of an appointed financial intelligence unit delegate and two of them approvals of records of proceedings for the European Parliament, from the meetings of May and June 2025. Those are the records of proceedings that Article 6(19) of the Board’s Rules of Procedure requires. Twenty-five Member States attended, Denmark and Finland absent, with Iceland, Liechtenstein and Norway as observer states and the Commission present; no Union observer institutions are listed.

Moving a mandate needs the Commission’s agreement

The draft Single Programming Document for 2026 to 2028 was discussed here, three months before its planning annex became the schedule everything is now measured against. Members largely agreed the priorities and pressed for a phased approach treating the financial and non-financial sectors on different timings, because of how heterogeneous the second is. They asked that ambition be calibrated carefully and that sequencing reflect resource constraints and the state of AMLA’s risk methodology.

The European Commission supported prioritising the work most relevant to the supervisory community and the single rulebook, and cautioned against deprioritising the non-financial sector, given its importance for the co-legislators.

The Chair’s conclusion contains the sentence that matters. The non-financial sector is important to the system and it is fundamental to get the risk assessment models and rules right; given the sector’s heterogeneity the drafting must be careful, proportionate and business-tailored. And then: any reprioritisation of mandates, financial sector or non-financial sector, will need to be discussed and agreed with the European Commission.

Written comments were due by 24 October 2025, with adoption by the Executive Board by the end of November and publication after that.

The crypto workstream, and what the Member States asked to be in it

AMLA set out a two-phase plan on convergence and effectiveness in the crypto-asset sector during the transition to the Markets in Crypto-Assets Regulation: evidence gathering and analysis with competent authorities and financial intelligence units, leading to a strategic report, followed by joint thematic reviews or targeted analyses. The aim was to deliver the first strategic analysis in spring 2026.

The list members asked to have covered is the useful part, because it is a list of what supervisors were worried about in late 2025. Beyond crypto-asset service providers: asset-referenced tokens and electronic money tokens, decentralised finance, crypto automated teller machines, cross-border risks, the travel rule, nested and correspondent arrangements, offshore jurisdictions, and unauthorised activities after the transition. They asked for complementarity with other authorities’ work and warned against duplication. From the financial intelligence side, members welcomed questionnaires and an expert network, while noting the network could follow the first analytical outputs rather than precede them.

A conflict of interest policy, and a question about its reach

The Board was consulted, as the Regulation requires, on the draft rules for preventing and managing conflicts of interest concerning the Chair and the other members of the Executive Board. Members asked two questions about reach: does it apply to financial intelligence unit delegates, and does it apply to prospective members of the internal committees.

AMLA’s answers were that the delegate question would be dealt with in the rules on seconded national experts and on delegates’ rights and obligations, due at the next meeting, and that the policy does not apply to members of the internal committees.

The housekeeping

The 2026 meeting calendar was sent back to be refined, members having flagged clashes with international engagements in February, April, late June and early July and asked that physical meetings in February be limited. The update on organisational developments, human resources and information technology, was taken in writing because the meeting ran short of time. Twenty-seven Member States attended, four with their supervisor alone and Slovakia with its financial intelligence unit alone; the observer institutions were the European Central Bank, EIOPA, Europol, Eurojust, the EPPO and OLAF, jointly the fullest observer attendance in this record.

The non-financial sector arrives, and is split off

Responsibility for the non-financial sector workstreams passed from the European Commission to AMLA in September 2025, after preparatory work running since April 2024. AMLA set out what was in the inheritance: draft standards on the risk assessment methodology for obliged entities, on the gravity of breaches, and on customer due diligence, to be taken forward through working groups and the expert network.

The Board then made a choice whose consequences run through everything after it. Members favoured separating the financial-sector and non-financial-sector processes, to tailor the work and avoid delays. They pressed sector specificity, warned against aiming for the lowest common denominator, and cautioned against reusing financial-sector frameworks directly in the non-financial sector. It was noted that splitting the processes is legally feasible where justified, while the statutory deadlines remain unchanged.

Weights and thresholds, already the live question

On the handover from the EBA, the EBA set out its transition priorities, continuity of activity, the transfer of systems, data and knowledge, and stronger cooperation arrangements, while AMLA reported on receiving deliverables, finalising mandates from the call for advice, transferring the central reporting database and its tools, and absorbing the documentation.

What members asked for is the part worth keeping. They pressed AMLA to move quickly on the financial-sector risk assessment methodology and the selection for direct supervision, focusing on calibration, thresholds and weights rather than revisiting data points. They supported an AMLA-coordinated working group, asked for timely communication to industry and to national authorities, and backed public consultation. On customer due diligence they wanted a risk-based, proportionate approach and warned against adding requirements beyond what is necessary.

Two committees are created

The Board approved by consensus the establishment of an internal committee on private-sector standards and an internal committee on the functioning of the supervisory system, the two bodies through which most of AMLA’s mandates are now delivered. Operational procedures were to come in December for a launch at the beginning of 2026.

Members welcomed joint chairing as a way of strengthening ownership, and asked for flexible membership and attention to the non-financial sector. They set three limits. The committees should steer rather than duplicate existing working groups. They should concentrate on strategic matters without pre-empting General Board discussions. And they should prioritise the most urgent deliverables, given how many mandates there are. They also supported involving observers.

What the Member States asked of the database, and a standard already in trouble

On policy mandates and the first steps towards indirect supervision, members asked for three specific things about the central AML/CFT database: greater granularity in the reporting of sanctions and breaches, clear technical requirements so that national authorities can automate, and safeguards consistent with the General Data Protection Regulation. They also pressed for timely coordination on the cooperation instruments for direct supervision and for home and host interactions.

And they flagged a standard that was already proving difficult. Some members noted trouble agreeing on the regulatory standard under Article 19(9), on thresholds and the criteria for identifying business relationships, occasional transactions and linked transactions, pointing to divergent interpretations at national level.

Separately, AMLA set out the questionnaire it would circulate under Article 9 of its Regulation to collect the thematic reviews supervisory authorities planned for 2026, with the results feeding a consolidated plan for the December meeting. Some members found the deadline awkward against their own scheduling cycles; AMLA said the timeline follows the Regulation and that provisional entries were acceptable.

The housekeeping

Three written procedures are annexed, and two of them are records of proceedings prepared for the European Parliament, from the meetings of May and June 2025. Twenty-six Member States attended, Sweden absent, with Iceland, Liechtenstein and Norway as observer states and the EBA, the European Central Bank and EIOPA as observer institutions.

The risk model and AMLA’s fee income

The EBA presented the state of its work under the Commission’s Call for Advice, received in March 2024, covering four draft standards: the assessment and classification of the inherent and residual risk profile of obliged entities and how often it must be reviewed, the risk assessment for selection for direct supervision, customer due diligence, and pecuniary sanctions and administrative measures. Discussion centred on what the EBA would hand to AMLA by the end of October 2025.

Then the Commission’s representative made the connection that explains a great deal of the urgency in the meetings that follow. A full methodology for selecting the forty entities, including its testing, was expected and important, and AMLA’s budget depended on it. Activating fees requires the Commission to submit a delegated act on how the fees are calculated. That act is based on the methodology, so any delay would prevent AMLA from starting to collect fees.

AMLA’s interim Executive Director acknowledged the concerns while noting that AMLA might have to carry out the testing in record time to meet all the requirements, and that industry wanted clarity. The EBA’s Executive Director, observing that the EBA’s own resources were scarce, offered EBA support for a dry-run on the model in 2026. The Chair concluded that AMLA’s 2025 and 2026 work and planning would be significantly affected by how much remained for AMLA to devise, develop and execute on the risk models after the handover.

Managing expectations on deadlines, as the key concern

On the draft work programme for 2025, members welcomed efforts to simplify the document and make it less legalistic, and supported prioritising the risk assessment methodology. The summary then records that managing expectations on deadlines emerged as the key concern, also as part of transparency efforts, and some members underlined the difficulty of planning for 2026 given the already significant workload for 2025.

The Chair concluded on the need to keep the super priorities under close review and to assess continually what AMLA could deliver in its early start-up phase. AMLA noted that it remained conscious of its limited staffing resources. Two programming documents were announced here for the first time: the 2026 to 2028 annual and multiannual programming, and the 2027 to 2029 multiannual programming.

Who does what on the Executive Board

The other members of the Executive Board joined AMLA on 2 June 2025 and held their first official meeting on 13 June, selecting Juan Manuel Vega Serrano as Vice-Chair and adopting their rules of procedure. The division of work, agreed informally, is set out in full and is the only published account of it in this record.

Mediation and peer review, at the drafting stage

Both instruments for the financial intelligence pillar were being built here, and the summary gives their legal bases and their shape.

Mediation, under Article 46, empowers AMLA to facilitate mediation between units where they disagree about cooperation on individual cases. Experts from the units of Greece, Hungary and Italy were drafting rules covering the conditions for a request, the steps and timelines for AMLA’s initial assessment, the role of the Board in this composition, the issuance of a non-binding opinion and the follow-up, and confidentiality and data protection. Members raised the Egmont Group’s own mediation process and asked what would happen if two mediations ran in parallel, one in Egmont and one in AMLA. The team undertook to follow up.

Peer review, under Article 48, is AMLA’s task of promoting best practice and strengthening operational effectiveness and consistency among the units. The work plan covered two cycles, July 2025 to July 2026 and July 2026 to July 2027, both prepared as pilot projects under the transitional framework. Members warned against duplicating the mapping work already done by Egmont, by the Italian unit some years earlier, and through MONEYVAL and the FATF. On thematic reviews they warned against focusing on particular predicate offences, because the level of risk attached to an activity rests on each national risk assessment and those differ, so the resources each unit devotes to a given offence differ too.

Three smaller things that dated well

The first joint analysis nearly had a crypto subject. In presenting the roadmap, AMLA noted the selection of a topic, with crypto-assets one option to be considered, given that it had been identified as a priority and as the most risky sector in the supervisory pillar too. Members pushed for speed, including the transfer of work from the FIU Platform, the Commission’s expert group on financial intelligence matters, and for AMLA to be given an operational node on FIU.net.

The delegates arrived on a schedule. The first delegates were to be onboarded in September 2025, and half of them by January 2026.

Two memoranda were legally due within ten days. Articles 91 and 92 of the Regulation required AMLA to conclude, by 27 June 2025, memoranda of understanding with the European Supervisory Authorities and with the European Central Bank. Both drafts were still to be circulated to the Board after this meeting. The Chair observed that anti-money laundering and prudential risks are deeply intertwined, which made the two essential.

On mutual assistance under Article 45, members supported a simple and efficient mechanism and, noting that nobody could yet foresee how many requests AMLA would receive, suggested building in criteria for prioritising incoming requests.

A note on this document

This summary is not like the others. It was issued on 6 October 2025, almost four months after the meetings, under the Chair’s own name, and it is structured as Issue, Discussion and Outcome rather than as Discussion and Conclusion. More to the point, it names people: the Vice-Chair and every member of the Executive Board with their portfolios, and the Member States whose experts were drafting the mediation rules. Later summaries are generally less detailed: they rarely name Member States and, under Article 6(20) of the Rules, omit the list of decisions. Is this the intended format going forward?

The only summaries that count the votes

Five decisions are recorded here with full tallies; later summaries give counts only occasionally. The Board may admit observers beyond those the Regulation names by a two-thirds majority of its voting members, and it used that power on the three EEA and EFTA states, Iceland, Liechtenstein and Norway, temporarily until the package is incorporated into the EEA Agreement.

Members raised a doubt about the legal basis for bringing the three states into the pillar before incorporation, including into joint analyses and the standing committee, and noted that Liechtenstein and Iceland were not yet part of FIU.net. The decision passed subject to the legal basis being checked.

What the Commission kept

The Commission set out the division of labour, and the list of what it does not hand over is the useful half. Transferring to AMLA: FIU.net, the policy work the FIU Platform had been doing, and the non-financial sector coordination work on Level 2 measures. Staying with the Commission: assistance to Member States on transposing the Directive, and its own Level 2 mandates on beneficial ownership registers, bank account registers, high-risk third countries, politically exposed persons and the collection of statistics, plus two specific mandates on the calculation of fees and on the procedure for imposing pecuniary sanctions and periodic penalty payments.

On FIU.net, the Commission wanted preparation started at once, targeting completion of the transfer by July 2027 at the latest and ideally at the beginning of 2027. The expert group working on the non-financial sector Level 2 mandates was scheduled to expire in October 2025. The EBA confirmed it aimed to submit its response to the Call for Advice by the end of October 2025.

The first joint analysis was expected by the end of 2025

The Regulation required the financial intelligence pillar to be operational from 1 July 2025. On that basis AMLA told the Board that a first pilot joint analysis would probably take place by the end of that year, and that peer reviews would for the time being focus on understanding best practice between units.

Members called the plan ambitious, which made prioritisation more necessary, and observed from experience that joint analyses take a very long time. They pressed for synergies between the units and supervisors on systemic issues, giving virtual IBANs as the example, and for IT tools that keep exchanged data confidential and secure. On peer review, some argued AMLA could explain and defend the European model of financial intelligence units inside the FATF and MONEYVAL, and that reviews should spread good practice and harmonise standards, noting how well some European units already score in FATF evaluations.

Building an authority

The interim Executive Director described the state of the Authority in May 2025. AMLA might not reach the 120 staff by the end of 2025 that the legislative statement in the Regulation envisaged, though the final figure was likely to be close. The digital workspace was done, with the Commission’s help. The specific IT business solutions, aimed at automated data gathering and analytical capability including artificial intelligence, were still missing three things. These were the sources and exact data sets that would feed the databases, the details of the risk methodology, and the incoming Executive Board’s views on sensitive matters such as data governance.

On money, AMLA was still operating under the Commission’s umbrella through the financial circuits of DG FISMA, and would become fully autonomous from 1 January 2026, with substantial financial support from the German authorities in the early years. The seat is the Messeturm, on a lease negotiated as a fifteen-year commitment and as a joint project with EIOPA; the conference floor where the Board meets in person was expected to be ready around March 2026.

Members pressed on recruitment: diversity and equal opportunity across all Member States, the specific challenges of low-capacity authorities, and a request not to lean too heavily on the inter-agency recruitment channel. On the work programme, they asked that it be written for the general public, since it would be AMLA’s first public self-description. On simplification, they asked that it be acknowledged there will be adaptation costs. And on fees they said budgetary independence through charges on obliged entities was crucial but complex, and that AMLA should draw on the experience of the Single Supervisory Mechanism and the Single Resolution Board. The Chair’s answer on hiring named the skills she wanted beyond anti-money laundering experts: statisticians, mathematicians, macroeconomists, crypto experts, payment experts.

A basic concept that does not travel

Presenting the supervisory work programme, the Risk and Measures Team named the difficulty plainly: accommodating basic concepts that are familiar in the financial sector to the non-financial industry, the concept of a business relationship among them, and adapting the business-wide risk assessment to the size of an obliged entity without losing substance. The Supervisory Processes Team named its own challenges as the short legal deadlines and the need to continue the work the EBA and the Commission had begun, and reported the identification of super-priorities.

Members’ main concern was the methodology for selecting the forty entities. They also raised something structural: Member States are evaluated against different methodologies from the FATF, MONEYVAL and the EBA, and asked AMLA to help address that.

Committees, working arrangements, and two memoranda

Five Standing Committees were proposed and thought ambitious, though the business case for each was not challenged. There was clear support for a joint committee on IT, Suptech and Regtech, and for separating financial and non-financial sector supervisory practice. Who would chair them was raised. The Chair described a standing committee as a bridge between technical workstreams and the Board, so that the Board can concentrate on strategy, explicitly on the model of the EBA’s anti-money laundering standing committee and its Board of Supervisors. The dossier was not considered urgent. In the financial intelligence composition the day before, some members had opposed a joint committee on IT precisely because the units’ IT problems are specific.