AMLA’s Deterrence Gap: Weak Fines, Weak Impact AMLA is presented as Europe’s answer to fragmented and ineffective anti-money laundering supervision. A Union-level AML supervisor is necessary. But a supervisor’s effectiveness does not depend only on its mandate. It depends on consequences. Recent criticism of the EU’s AML reform increasingly questions
AMLA’s direct-supervision criteria may miss smaller high-risk banks, EMIs, PSPs and acquirers that enable cross-border fraud despite not meeting size or six-Member-State thresholds
The uncomfortable question is no longer whether banks had AML policies. The question is whether their published claims of group-wide control were ever tested against operational reality. A new EU standard exposes an old credibility problem Large European banking groups have told investors, regulators and the public for years that
The package of legislative proposals On 21 July 2021, the European Commission presented a package of legislative proposals aimed at combating money laundering, terrorist financing, and sanctions evasion. This proposed AML/CFT package consisted of four draft legislative acts: The EU “single rulebook” Regulation (“AMLR”) : contains provisions on conducting customer
