The EU's bet on unified supervision against financial crime

The new supervisory mechanism begins its operations in Frankfurt. Expectations are high for combating dirty money. Written by Spyros Papathanasiou and Maria Kaini.

The EUs bet on unified supervision against financial crime

This article is an AI translation of an original piece published in Greek. Read original

On June 9, 2025, in Frankfurt, the Anti-Money Laundering Authority (AMLA) held its first official conference.

This date may prove historic for European financial supervision. For the first time, the European Union is attempting to create a truly unified coordination mechanism against money laundering from illegal activities. The question is whether the new Authority can succeed where, for decades, national supervisory authorities struggled to cooperate effectively.

The European Union is entering a new phase with regard to the prevention of money laundering from illegal activities and the financing of terrorism (AML/CFT). At the center of this transition is AMLA (Anti-Money Laundering Authority), the new European authority that aspires to reduce divergences between national supervisory regimes and strengthen the coherence of the Union framework.

This development does not have only administrative or organizational significance. It concerns the very way in which Europe perceives financial integrity, transparency, and cross-border supervision within the single market.

For a long period of time, the Union relied on a regulatory system in which the basic principles were common, but their implementation remained significantly differentiated. The differences between member states regarding the interpretation of obligations, supervisory practices, and cooperation mechanisms limited the effectiveness of the overall European approach.

Directive (EU) 2024/1640 (AMLD6) itself acknowledges that previous experience revealed substantial differences in the practices of the competent authorities and inadequate arrangements for cross-border cooperation. In this sense, AMLA constitutes an institutional response to a structural problem of European integration in the AML/CFT sector.

Reform

The current reform has a clear legislative basis. Directive (EU) 2018/843 (AMLD5) had already pointed out that new forms of risk required adaptation of the European framework.

The directive emphasized that effective prevention depends on increasing transparency in the Union's economic and financial environment, especially in relation to corporate structures and other legal forms that can be used for the concealment of assets or the true identity of those who control them.

Addressing money laundering is not exhausted by the detection of suspicious transactions, but also presupposes reducing the opacity that allows them to develop.

In the same spirit, AMLD5 placed particular emphasis on technological developments. The inclusion of providers of exchange services between virtual and fiat currencies, as well as providers of custodial digital wallets, within the scope of Union legislation was particularly important.

The European legislator recognized that the relative anonymity of virtual assets could create additional risks and that the competent authorities had to acquire appropriate tools for monitoring and analyzing the relevant transactions. As early as 2018, it had become clear that financial supervision cannot be limited to traditional banking tools.

Supervision

Directive (EU) 2024/1640 is part of a broader package of reforms that constitutes the Union's new AML/CFT legal and institutional framework and explicitly supports the creation of AMLA. The critical element is the shift from a regime of mainly national implementation of directives toward a model of stronger harmonization, institutional coordination, and common supervisory reference.

Of particular importance is the fact that the new package is not based exclusively on Directives requiring national transposition, but also includes the Anti-Money Laundering Regulation (AMLR), which applies directly and in a harmonized manner in all member states. This choice aims to reduce the divergences that characterized the previous regime and significantly strengthens the degree of harmonization of the rules at the European level.

The new Authority is not expected merely to monitor the implementation of the rules. It undertakes to function as a European hub of supervisory consistency, cross-border cooperation, and the development of common methodologies.

Money laundering from illegal activities and the financing of terrorism are quintessentially cross-border phenomena. They exploit divergences between legal orders, different levels of supervisory intensity, and weaknesses in information exchange.

When economic activity is unified but prevention remains fragmented, the system becomes vulnerable precisely at the points of lowest cohesion. AMLA seeks to reduce these asymmetries and strengthen the functional unity of the European area.

Transparency

Of particular importance is the emphasis that the new framework places on beneficial ownership registers. Directive 2024/1640 considers these registers crucial for preventing the abuse of legal persons and legal arrangements. Beneficial ownership data must be collected and maintained in central registers, in a usable and machine-readable format.

Even more importantly, member states must ensure the adequacy, accuracy, and timeliness of these data, as well as the existence of procedures for verifying and correcting inconsistencies.

The importance of beneficial ownership registers has also been highlighted by the case law of the Court of Justice of the European Union, which has underlined the need for balancing between the pursuit of transparency and the protection of personal data and fundamental rights. The discussion, therefore, concerns not only the availability of information but also the conditions of access to and use of it.

This approach reflects a substantial shift in Union AML/CFT policy. Attention is no longer directed exclusively to the transaction, but also to the legal and economic structure through which it is carried out. The critical question is not only what amount was moved, but also who is behind the legal person appearing on the surface of the transaction.

Access

The new framework is not limited to the creation of registers, but also regulates the issue of access. Financial Intelligence Units, supervisory and judicial Authorities, as well as the relevant Union bodies, must have direct and effective access to information regarding (beneficial) ownership. This access is critical for the prevention, detection, investigation, and prosecution of related offenses.

AMLA itself is envisaged to have access to this information in the exercise of its supervisory mission, which strengthens its role as a central institution of the new European framework.

Stake

Despite the clear direction of the reform, its success cannot be considered a given. The key question is whether the new architecture will manage to combine harmonization with proportionality and effectiveness.

A framework that is excessively rigid or excessively formal may reinforce merely bureaucratic compliance without substantially improving the capacity to detect and prevent the relevant risks.

By contrast, a system that invests in transparency, in the interoperability of information, in data quality, and in cooperation between the competent Authorities, but also between the competent compliance functions of supervised entities, can substantially upgrade the European capacity for prevention.

The real challenge for AMLA is not to issue new guidelines nor to create additional compliance procedures. It is to prove that Europe can function as a single supervisory area against criminal networks that already operate without borders.

If it succeeds, it will substantially strengthen the credibility of the European financial market. If it fails, AMLA risks being added to the list of institutions with high expectations but limited practical impact.

 

* Spyros Papathanasiou is associate professor of finance, Department of Economics, National and Kapodistrian University of Athens.

** Kaini Maria is a doctoral candidate at the National and Kapodistrian University of Athens. Regulatory Compliance Directorate, Alpha Bank

v
Privacy