European Union: Money Laundering

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Article
Following The Money: The Commission Maps The Next Phase Of EU Financial-Intelligence Access
The European Commission has published its first report on Directive (EU) 2019/1153, mapping the evolving framework for law-enforcement access to financial intelligence across the EU. While the report defers decisions on expanding data access, it signals a shift toward faster, more standardized cross-border information sharing through interconnected account registers and structured transaction formats. Financial institutions face mounting pressure to ensure their data governance, production capabilities, and
Germany Government
PL
PwC Legal Germany
Article
Den Geldströmen Auf Der Spur: Die EU-Kommission Skizziert Die Nächste Ausbaustufe Des Zugangs Zu Finanzinformationen
The European Commission has released its first report on the use of financial information by law enforcement authorities, nearly two years behind schedule. While creating no immediate new obligations for financial institutions, the report clearly signals a future direction: networked account registers, standardized transaction data, and faster cross-border inquiries. As data architecture becomes increasingly integrated while the legal framework remains fragmented, financial institutions must understand the
Germany Government
PL
PwC Legal Germany
Article
Bafin Raises The Bar On Virtual IBAN Compliance
Germany's financial regulator BaFin has issued new supervisory guidance on virtual IBANs, addressing concerns about transparency in payment flows and beneficial ownership while affirming that vIBANs remain legitimate payment infrastructure. The communication requires firms to demonstrate that their governance, customer transparency and monitoring arrangements have kept pace with technological innovation, particularly in relation to anti-money laundering and counter-terrorist financing controls.
Germany Finance
PL
PwC Legal Germany
Article
Netherlands – Investment Bank Fined €8.5m For Compliance Failures, Including Sanctions
The Dutch central bank has imposed a significant financial penalty on ABN Amro for failures in its customer due diligence processes, particularly concerning high-risk clients. The investigation revealed critical gaps in the bank's ability to identify and address potential sanctions evasion involving dual-use goods and intermediaries in high-risk jurisdictions.
Netherlands Government
DM
Duane Morris LLP
Article
MFSA’s Thematic Review On TF, PF And Sanctions Evasion: Key Findings And Implications For Credit Institutions
The Malta Financial Services Authority has issued new supervisory guidance following a thematic review of how credit institutions identify and mitigate terrorist financing, proliferation financing and sanctions evasion risks. The review reveals significant gaps in proliferation financing frameworks and sets clear expectations for governance, risk assessment, transaction monitoring and the responsible deployment of artificial intelligence in financial crime compliance.
Malta Finance
GA
Ganado Advocates
Article
Jenec And The Limits Of Automatic De-risking In EU Banking Law
The Court of Justice of the European Union has ruled that banks cannot automatically refuse to open basic payment accounts solely because an applicant appears on a third-country sanctions list, such as OFAC. While such designations constitute relevant risk factors, financial institutions must conduct individual, proportionate assessments demonstrating that AML and sanctions-related risks cannot be adequately managed through appropriate measures.
Cyprus Finance
EN
Elias Neocleous & Co LLC
Article
New Italian AML Requirement: Bank Of Italy Mandates Notification Of The AML Responsible Officer
Italy's Bank of Italy has introduced a mandatory notification requirement for the appointment of AML responsible officers, effective July 2026. Obliged entities under the Bank of Italy's supervision must now communicate appointments and changes within specific timeframes through designated procedures. This analysis provides a comprehensive Q&A format breakdown of the new requirements, communication modalities, and critical compliance deadlines that financial intermediaries must meet.
Italy Finance
AO
A&O Shearman
Article
Jenec: The Limits Of Automatic De-Risking In EU Banking Law
On 11 June 2026, the Court of Justice of the European Union (the “Court”) delivered its judgment in Case C-81/24, Jenec. The case concerned the relationship between the right of access to a payment account with basic features under Directive 2014/92/EU (the “Payment Accounts Directive”) and the AML/CFT obligations imposed on financial institutions under Directive (EU) 2015/849 (the “AML Directive”).
Cyprus Finance
EN
Elias Neocleous & Co LLC
Article
Ireland’s AML/CFT Action Plan: 2026 – 2027
Ireland's Department of Finance has released its third National Risk Assessment on Money Laundering, Terrorist Financing and Proliferation Financing, identifying very significant risks in retail banking, digital banking, crypto-assets, and payment institutions. The assessment is accompanied by a comprehensive 30-Point Action Plan designed to strengthen Ireland's financial crime response framework over the next 18 months through enhanced regulatory oversight, beneficial ownership transparency, and sector-spe
Ireland Finance
AC
Arthur Cox
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