The European Banking Authority (“EBA”) published its Final Report on Competent Authorities’ Approaches to the Anti-Money Laundering (“AML”) and Countering the Financing of Terrorism (“CFT”) Supervision of Banks (EBA/REP/2025/27) in October 2025, following reviews of 40 National Competent Authorities (“NCAs”) from 2018 to 2024.
The report highlights substantial progress in supervisory strategies, tools, and cooperation mechanisms, while also identifying persistent gaps in risk assessment and enforcement. These findings will inform the implementation of the new EU AML/CFT framework. As Money Laundering and Terrorist Financing (“ML/TF”) risks evolve amid geopolitical instability and technological advancement, the EBA underscores the urgent need for consistent, risk-based supervision that safeguards the financial system and ensures alignment with Financial Action Task Force (“FATF”) standards. The consequences of non-compliance include heightened enforcement, reputational damage and potential supervisory interventions, particularly for cross-border banking groups.
Key Developments
Advancements in AML/CFT Supervisory Frameworks
The EBA’s reviews reveal NCAs’ increased efforts to embed AML/CFT into core supervision, with notable enhancements covering:
- Implementation of integrated AML/CFT supervisory strategies and annual plans, aligned with National Risk Assessments (“NRAs”) and the EBA’s Supranational Risk Assessment (“SNRA”);
- Updates to supervisory manuals and tools incorporating EBA Guidelines on risk-based supervision, with expanded use of off-site monitoring, thematic reviews, and data analytics;
- Ongoing integration of AML/CFT considerations into the Supervisory Review and Evaluation Process (“SREP”) under the Capital Requirements Directive IV (“CRD IV”).
Strengthening Cooperation Mechanisms
- Cooperation remains a central pillar of effective supervision. The report identifies improvements in both domestic and international collaboration:
- Domestically, NCAs have formalised relationships with Financial Intelligence Units (“FIUs”) and other authorities through memoranda of understanding and joint supervisory committees, enabling enhanced information sharing regarding suspicious activity;
- Internationally, progress has been made through bilateral arrangements with third-country supervisors and the use of AML/CFT colleges to oversee cross-border banking groups.
Nevertheless, supervisory challenges persist, particularly regarding oversight of foreign bank branches and assessing global ML/TF exposure.
Importance of Compliance and Applicable Regulations
The EBA underscores the importance of a risk-based approach under the forthcoming EU AML Regulation (“AMLR”) and Sixth Anti-Money Laundering Directive (“AMLD6”), which aim to harmonise risk assessments, supervisory measures, and enforcement across Member States.
Relevant regulatory texts include:
- EBA Guidelines on ML/TF Risk Factors (EBA/GL/2021/02),
- Guidelines on Internal Governance (EBA/GL/2021/05),
- Guidelines on the Assessment of the Suitability of Members of the Management Body and Key Function Holders (EBA/GL/2021/06),
- CRD V, and
- The establishment of the new Anti-Money Laundering Authority (“AMLA”), whose supervisory remit will begin in 2026.
Firms should prepare for increased regulatory scrutiny, particularly where weaknesses in governance or supervisory cooperation are identified. Common areas of concern include under-resourced AML/CFT functions and gaps in data-sharing frameworks with third countries.
Proposed regulatory updates aim to improve consistency, including:
- Mandatory integration of AML/CFT into SREP assessments;
- Enhanced reporting through the European Reporting System for Material AML/CFT Weaknesses (“EuReCA”); and
- Revised guidelines governing the authorisation of financial institutions.
Regulatory Implications and Compliance Lessons
TThe EBA’s findings point to a maturing supervisory landscape and offer the following practical considerations for financial institutions:
- Align internal AML/CFT frameworks with NRAs/SNRAs, using EBA tools for ongoing monitoring and scenario testing.
- Establish robust memorandum of understandings for domestic FIU links and international colleges.
- Revise suitability assessments and internal policies per EBA Guidelines, integrating AML/CFT into Board responsibilities.
- Address NCA challenges by upskilling staff on digital ML/TF risks and leveraging data analytics for efficiency.
- Conduct gap analyses against AMLR/AMLD6 to ensure seamless transition to centralised supervision.
The report serves as a timely reminder of the intensifying ML/TF threats facing the sector, from trade-based laundering to sanctions evasion. A proactive compliance approach is critical to minimising disruption, maintaining market confidence and meeting supervisory expectations.
How Complyport Can Help
Complyport offers tailored solutions to support AML/CFT/CPF frameworks for banks and payments institutions, ensuring alignment with EBA standards. Our services include:
- AML/CTF/CPF Risk Assessments and Gap Analyses;
- CDD and EDD Policy Reviews;
- Cross Jurisdictional Rules Mapping;
- Operational Resilience and Private Key Management reviews;
- MiCA Authorisation Applications and CASP Compliance;
- Staff Training on EBA Guidelines, AMLR, and Digital ML/TF/PF Risks; and
- Regulatory Guidance and Compliance Advisory Support.
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