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MiCA, AMLA and AI: Compliance in Europe in 2025

Koos Couvée
Europe Editor
Gabriel Vedrenne
Senior Reporter

Despite pressure to follow its apparently erstwhile ally, the U.S., in dialing back oversight of financial services, the EU did what the EU does best in 2025—regulation—in launching a bloc-wide anti-money laundering supervisor and a sweeping new rulebook for cryptocurrency.

Beyond the financial services industry, the year brought more turbulence and uncertainty to the EU and Britain via widening political fragmentation, lopsided trade agreements with President Donald Trump’s White House and Russian offensives in Ukraine, not to mention contentious debates over artificial intelligence.

Cryptocurrency-related and technology-driven fraud and money-laundering schemes proliferated again in 2025, as investigators warned of growing criminal adoption of digital assets and use of AI to bypass know-your-customer protocols. More and More

In January, the EU’s new Anti-Money Laundering Authority began meeting with national regulators to plan the forthcoming overhaul of the bloc’s supervisory architecture in earnest, and finance ministers appointed veteran Italian central banker Bruna Szego as AMLA’s first chair. More and More

Frankfurt, Germany-based AMLA will set uniform standards for compliance and supervision across the EU, double as a data-sharing hub for national financial intelligence units, or FIUs, and from 2028 onwards directly oversee 40 of the EU’s highest-risk financial institutions as measured by their systemic importance and exposure to illicit finance.

The year opened with French regulators blacklisting fraudulent websites and warning of an exponential rise in cryptocurrency-related investment scams. More

In February, banks across the EU sought clarity over which and whose details they will have permission to share under a legal framework taking shape in July 2027. More

A Dutch court sentenced four Chinese nationals that month to a combined 29 years in prison for laundering tens of millions of euros for Colombian drug traffickers. More

Anita van Dis, national coordinator for asset recovery at the Netherlands Public Prosecution Service, told ACAMS moneylaundering.com that investigators deepened their understanding of complex money-laundering and underground-banking networks in 2025.

“The vast majority of transactions linked to drug trafficking are facilitated through a system of underground banking,” van Dis noted. “Investigations and intelligence show that if you want to combat organized crime, more attention must be paid to this.”

The Financial Action Task Force, also known as FATF, revised its technical standards in a bid to boost inclusion, and ramped up efforts to tackle transactions linked to online child sexual abuse and the proliferation of weapons of mass destruction. More, More and More

Swiss prosecutors fined Morgan Stanley $1.1 million for failing to prevent an employee from helping a former Greek official launder bribes. More

Banks breathed a sigh of relief in March after the European Banking Authority, or EBA, proposed to give them until 2032 to comply with new, EU-wide due-diligence requirements when handling clients who do not immediately carry a high risk of illicit finance. More

Helene Erftemeijer, a sector coordinator at the Dutch Banking Association, said her organization focused this year on ensuring that the EU promulgates regulatory technical standards, or RTS, on due diligence in “a risk-based and proportionate manner.”

“Since then, on balance, we’ve seen a real shift towards more of a risk-based approach,” Erftemeijer told moneylaundering.com. “That principle is now an explicit and central statement [in the draft RTS].”

AMLA chair Bruna Szego told moneylaundering.com in her first interview since taking office that she wants the agency to directly supervise a wide range of financial services companies and foster a “common culture” among national supervisors and FIUs. More and More

Max Braun, director of CRF, Luxembourg’s FIU, noted that AMLA’s arrival and bloc-wide AML reforms consumed a large share of the Grand Duchy’s resources this year.

“The main challenge is to be ready for the transposition and implementation of the AML package [in July 2027],” Braun told moneylaundering.com.

A regulatory inquiry in Lithuania linked to a high-profile embezzlement investigation ended with a record €8.4 million fine against the Vilnius-based Olympic Casino Group, the largest gaming establishment in the Baltics. More

Swiss officials warned that a 10 percent drop in manpower at the Federal Judicial Police forced prosecutors to abandon or decline thousands of cases over the past decade. More

French lawmakers approved draft legislation in April to subject professional soccer clubs and parties involved in selling and renting private jets to AML requirements, then called on their government to outlaw anonymous purchases of prepaid cards. More, More and More

OKX, the world’s fifth-largest cryptocurrency exchange, was fined €1.1 million for breaching AML requirements in Malta, six weeks after pleading guilty in New York to failing to register as a money services business and screen billions of dollars of transactions. More

In a victory for the European Commission, the EU’s top court deemed Malta’s policy of doling out “golden passports” to wealthy investors illegal. More and More

The second-largest lender in the Netherlands, Rabobank, failed to settle a long-running investigation into systemic AML violations, setting the stage for criminal proceedings in Amsterdam next year. More

In May, the head of Switzerland’s FIU warned that a tenfold increase in annual volume sof suspicious activity reports over the past decade had stretched his agency thin, despite the country’s overall total ranking low in comparison to those of other European nations. More

Long-term job vacancies continued to plague the FIUs of Croatia, Romania and other countries in 2025. More

National regulators voiced skepticism that AMLA could or would implement a more risk-based, flexible approach to supervision, and warned that the agency would more likely saddle financial institutions with additional tasks and expenditures. More, More, More and More

“Uncertainty can cause headaches,” said Joachim Kaetzler, a partner with the CMS law firm in Frankfurt. “The financial sector has been very busy with the new EU requirements and discussions have accelerated, but we are still waiting for the final version from AMLA.”

France’s central bank chief urged financial institutions to fight fraud by adopting “dynamic” transaction-monitoring systems that use AI and draw from multiple datasets. More

“The surge in massive data leaks and hacking has allowed fraudsters … to target an ever-growing number of victims, further fueling the fraud wave,” Yoann Briant, director of compliance at Coinhouse, a cryptocurrency exchange in Paris, told moneylaundering.com.

Dutch officials unveiled plans to give banks access to a government-run database holding the personal details of all local residents to promote compliance with the EU’s forthcoming, bloc-wide AML regulation.

Dutch banks pushed for enhanced data-sharing protocols with law enforcement in a bid to regear their compliance programs towards truly suspicious clients. More and More

“It was good to see things we’d been calling for for a long time reflected in [the government’s new AML action plan],” said Erftemeijer, the Dutch banking-industry representative. “We’ve had banks around the table, but also DNB [the central bank], the Data Protection Authority, the FIU … and we’ve made some really good steps forward.”

Oversight

AMLA became fully operational in July, marking its arrival as supervisor of supervisors by warning national regulators and VASPs alike to tackle cryptocurrency-related illicit finance. More, More and More

After nearly two years of wrangling, the European Parliament approved a plan to bring the EU’s list of “high-risk third countries” in line with FATF’s “gray list,” but only after the European Commission pledged to include Russia. More, More, More and More

The Dutch FIU warned that money laundering networks embedded in labor-intensive sectors that rely on undeclared workers had expanded, and in some cases helped overseas terrorists move funds and buy weapons. More

“Thanks in part to other partners in the chain, we’re able to understand the money laundering methods used by criminals,” said van Dis, the senior Dutch prosecutor. “This enables early intervention through … preventive measures.”

Regulators in France, Germany, Belgium and five other nations teamed up to procure new software for screening cryptocurrency transactions for signs of illicit finance, and French regulators warned fintechs, and neobanks especially, to plug gaps in their compliance programs to prevent fraudsters from using them to launder profits. More and More

HSBC Private Bank in Geneva was the subject of parallel investigations in Switzerland and France after allegedly playing a pivotal role in laundering $330 million stolen from Lebanon’s central bank. More

In August, Swiss prosecutors fined JPMorgan Chase & Co. $3.7 million for handling hundreds of millions linked to the 1MDB corruption and money laundering scandal in Malaysia. More

Emmanuel Genequand, head of regulatory and compliance services at PwC in Geneva, linked the uptick in AML-related enforcement in Switzerland to an upcoming evaluation of the country’s defenses against financial crime.

“A FATF inspection often triggers a burst of activity by public authorities,” Genequand told moneylaundering.com. “There is an end-of-2026 cut-off date for collecting statistics on supervision, convictions and legislative developments, [and a] greater number of institutions and compliance officers are being questioned and even brought before the courts.”

The EBA decried that regulators and financial services companies alike had largely failed to embrace AI and other new technologies for AML purposes, while the Egmont Group took additional steps to safeguard the independence of national FIUs and boost their expertise against cyber-fraud and other online threats. More, More and More

As the European Central Bank moved forward with plans to launch a digital euro, officials faced the difficult task of striking the right balance between respecting privacy and combating illicit finance. More

In September, the Bank of Lithuania fined Paysera, the largest electronic money institution in the Baltics, €400,000 for acquiring Contis, a now-defunct rival, without authorization. More and More

Dutch officials urged AMLA to finalize guidance on reporting potentially illicit transactions amid plans to bring their country’s unique system for flagging suspected financial crimes in line with the rest of the EU. More and More

Swiss lawmakers approved legislation to expand AML regulations in their country’s legal sector and establish a federal database of beneficial owners, but only after they substantially weakened the bill. More, More and More

In October, with the rollout of the EU markets in crypto-assets regulation gathering pace, the EBA outlined strategies that some virtual asset service providers have used to evade AML-related supervision. More and More

Briant, the head of compliance for Coinhouse in Paris, described the combination of MiCA’s arrival, new, EU-wide cybersecurity requirements and the bloc’s Transfer of Funds Regulation, also known as the “travel rule,” as a perfect storm for VASPs. More and More

“The regulatory pressure was high, to say the least,” Briant said.

Plans to create a new federal anti-financial crime agency and roll out other long-delayed reforms in Germany continued to stall, this time thanks to discord inside the country’s ruling coalition. More, More and More

“The previous government’s announcements were premature,” said Kaetzler, the attorney in Frankfurt.”There is now less political momentum for adding another administrative layer.”

France’s Commission Nationale des Sanctions assessed a record fine of €240,000 against an unidentified luxury retailer in Paris amid a broader campaign to strengthen AML enforcement in the country’s non-financial sector. More

Belgian supervisors and compliance officers endured withering questions from national lawmakers against a backdrop of money laundering scandals at the local branches of ING and Worldline, a payment service provider headquartered in Paris. More

FATF issued guidance to help governments implement the group’s new standards for recovering assets. More and More

In November, on the same day the Central Bank of Ireland assessed a record-high fine of nearly €22 million against Coinbase for breaching AML requirements, Germany’s BaFin fined JPMorgan Chase & Co €45 million, also a record, for taking too long to report suspicious transactions. More and More

Moneylaundering.com published details of how Kyrrex, a VASP licensed in Malta, and KuCoin, a much larger exchange in the Seychelles, tapped into the EU and U.K. financial systems, respectively, while running large offshore operations. More and More

A German-led investigation into a €300 million fraud and money laundering scheme underscored the threat posed by corrupt financial-services insiders. More and More

Braun, the head of Luxembourg’s FIU, which played a key role in the investigation, described the case as “a good example of our improved ability to analyze money laundering networks” through international cooperation.

“It’s interesting to consider what role AMLA could play in this type of case in the future,” said Braun.

Edmond de Rothschild became the first lender ever convicted of money laundering in Luxembourg after handling and hiding hundreds of millions of euros embezzled from Malaysia. The private bank agreed to forfeit €25 million. More

Monaco’s FIU outlined plans to lift the principality from FATF’s gray list. More

Weeks after the compliance chiefs of some of the largest banks in the Netherlands suggested that they anticipate an era of downsizing ahead, ING, the country’s leading financial institution by market share, started planning for layoffs. More

Britain

On the other side of the Channel, the Serious Fraud Office notched an early victory in January in gaining permanent custody of a £1.5 million luxury home in England’s Lake District bought with the proceeds of investment fraud. More

In April, a court in London sentenced a blacklisted ex-Russian official caught moving funds through an account at Halifax to six years in prison, bringing Britain’s first-ever prosecution of a suspected evader of sanctions against Russia to a successful conclusion. More

Officials then proposed a framework for resolving sanctions-related enforcement actions by way of early settlement, weeks after identifying the British Virgin Islands and Guernsey as key locales for schemes to evade commercial and financial embargos. More, More and More

The Financial Conduct Authority’s most high-profile action of the year came in July, when the agency, still facing a backlog of cases, fined Monzo Bank £21 million after finding significant deficiencies in the digital lender’s AML program. More and More

“Firms may break ground with new technology, frictionless onboarding journeys and new ways of doing things,” said Ruth Paley, a partner with Michelman & Robinson in London. “The lesson here was that you must have somebody riding with you who will tell you hard truths about whether these things actually fit with your regulatory obligations.”

The FCA then fined Barclays £42 million, citing due diligence-related failures stemming from the bank’s relationship with Stunt & Co, a gold dealership connected to a £200 million money laundering scandal that ended in March with four convictions. More and More

Ten years after launching the Joint Money Laundering Intelligence Taskforce, officials placed Data Fusion, a pilot program through which NatWest, Lloyds, Metro Bank and four other banks share and jointly review information on potentially illicit transactions with the National Crime Agency, or NCA, on permanent footing. More and More

Officials also updated their assessment of Britain’s financial crime-related risks and identified nine threats that will inform the AML priorities of government and the financial services industry alike in the near future. More, More and More

Adrian Searle, who led the NCA’s National Economic Crime Center until May, described the initiative as a “clear, determined attempt to get beyond ‘tick box’ compliance and focus private-sector capacity and capability on the things that really matter.”

“It’s fantastic that the FCA has been heavily engaged in it to give the banks confidence this is something regulators support,” Searle, now a senior associate fellow at the Royal United Services Institute in London, told moneylaundering.com.

In September, Zhimin Qian, mastermind of a scheme that defrauded tens of thousands of investors in China of £5 billion, pleaded guilty in London to laundering money in a case that marked Britain’s largest seizure of cryptocurrency to date. More

Officials announced that the FCA will begin directly supervising law firms, accounting practices and corporate services providers for AML purposes, thereby sidelining Britain’s current system of self-regulation for those businesses and professions. More, More and More

In November, the NCA linked a money laundering operation with a significant footprint in Britain to A7A5, a ruble-backed stablecoin allegedly linked to sanctions-evasion schemes that benefit the Russian military. More

“When you’re in a bank running your compliance systems, you’ve got to try to understand this intersection between traditional criminality and higher-end organized crime, which may link back to state or at least pseudo-state activity,” said Searle. “This is tricky stuff.”

Britain ended the year by unveiling a new strategy against corruption as the NCA sought to locate and restrain the assets of Bangladeshi elites accused of graft. More and More

Contact Koos Couvée at kcouvee@acams.org and Gabriel Vedrenne at gvedrenne@acams.org

Topics : Anti-money laundering , Fraud , Counterterrorist Financing , Sanctions
Source: United Kingdom , European Union
Document Date: December 15, 2025