AMLA launches with big promises!
As of 1 July 2025 the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has opened its doors in Frankfurt am Main, the seat fixed in the founding Regulation (EU) 2024/1620. Its first chair, Bruna Szego, and an executive board drawn from four Member States took office earlier this year, and political leaders hailed the launch as “a milestone for the European financial system”.
And yes, AMLA can become the long‑missing strike‑force—but only if it uses its sticks early and visibly. Otherwise it risks joining the alphabet soup of EU bodies that observe, coordinate and consult while professional money laundering keep unfolding in Europe.
Unfortunately, our experience over the past four years—marked by weak enforcement from BaFin (Deutsche Bank, Wirecard, Deutsche Handelsbank), the Dutch DNB (Payvision) and the Danish FSA (Københavns Andelskasse, Clearhaus A/S)—leaves us highly sceptical.
1 Europe’s AML problem ≠ too few authorities, but too little enforcement
Europe has already more than enough supervisory authorities with poor results on money laundering enforcement:
A report delivered by the European Court of Auditors in May 2021 found that the pre‑AMLA landscape was already crowded—Commission (DG FISMA), European Banking Authority (EBA), ECB/SSM, 27 domestic supervisors (NCAs) and FIUs—yet “institutional fragmentation and poor coordination” meant risks were rarely acted upon and breaches of Union law were not pursued in time, or at all.
Infringement data bear this out: by 2023 the Commission had opened procedures against every Member State over faulty transposition or application of AMLD 4 and 5.
When penalties are imposed, they come mainly from outside the EU: in 2024 US regulators levied 90 % of the world’s bank‑related AML fines ($4 bn of $4.5 bn), while the entire EU (ex‑UK) levied around € 300m.
Transparency international warns that inside the EU, monetary sanctions still “amount to rounding errors in big‑bank budgets” and that political pressure will push AMLA to keep fines low.
Bottom line: Europe’s scandal list (Danske, Wirecard, ABLV, Pilatus, Nordea, Оlaundromat) was not caused by a legal‑architectural gap but by supervisors that saw the smoke and failed to call the fire brigade.
What AMLA says it will do about enforcment!
- Targeted direct supervision.
Under Articles 12-20 of Regulation 2024/1620, AMLA must draw up a list—every three years—of at least forty credit or financial institutions that operate in six or more Member States and present a high ML/TF-risk profile; from January 2028 onward these groups will be examined by joint supervisory teams led by AMLA staff who may carry out on-site inspections, general investigations and, where breaches are found, impose administrative measures and pecuniary sanctions of up to 10 % of annual turnover or €10 million, whichever is higher. - Escalation when national supervisors fail.
With immediate effect, AMLA can launch a breach-of-Union-law procedure whenever it believes a domestic authority is not applying EU AML/CFT rules properly; if, after a binding recommendation, the supervisor still does not act, the Commission may transfer the entire supervisory file to AMLA, enabling it to issue direct instructions to the firm concerned. - Peer-pressure through systematic reviews.
Beginning in 2026, the Authority will conduct regular peer reviews and thematic inquiries of all national AML supervisors (financial and non-financial alike), publish comparative performance reports and, where it spots shortcomings, address individual recommendations or corrective action plans designed to raise supervisory intensity across the Union. - Joint inspections with the ECB and other EU bodies.
A Memorandum of Understanding signed on 3 July 2025 commits the ECB’s Single Supervisory Mechanism, the three European Supervisory Authorities (EBA, EIOPA, ESMA) and AMLA to share data, coordinate work programmes and, from 2026, run pilot joint on-site missions so that prudential and AML examiners visit the same institution together instead of duplicating effort.
Reasons why we are sceptical:
Another four years of (non-existent) enforcement with the (ineffective) local supervisory authorities:
Until 2028 every supervisory failure must still be fixed locally; AMLA can only escalate after breach is proved. Rogue banks thus enjoy at least one entire supervisory cycle before real EU‑level intervention.
Limited scope:
Right now Europe has around 4.000 PSPs so only 1% will be supervised by AMLA.
Governance vulnerabilities remain:
Following the Danske Bank scandal, when around €200 billion was laundered through the bank’s Estonian branch, the European Banking Authority (EBA) launched an investigation as to whether EU law had been breached. However, the formal investigation was shut down by the EBA’s Board of Supervisors, which consists of national representatives. But the AMLA must avoid placing national interests above its own The new Authority still gives 27 national heads voting rights on its General Board; lobbying concerns remain
Resources versus mandate:
Planned head‑count ~400. The US OCC & FinCEN together field >3 000 AML examiners for a smaller banking population. Execution risk is obvious.
Our Summary
For now, we remain highly sceptical. The Authority is launching with fewer staff than a mid-sized national supervisor, is at least four years away from issuing its first direct fine, and still has to build an enforcement culture from scratch. We therefore anticipate little genuine progress from this much-heralded European body—likely just another drain on the European taxpayer’s money.
The only bright spot is that neither the originally proposed Dutch candidate, Jan Reinder de Carpentier, nor Germany’s Markus Pleyer—the former FATF president—will be heading the new authority. Perhaps the newly appointed chair, Bruna Szega, will prove to be a positive surprise. Here’s hoping
