The Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) published a summary of the meeting of the General Board in FIU composition on 13 and 14 May 2025, Frankfurt, Germany. Topics where amongst others:

• “European Commission / EBA information about the state of play of ongoing workstreams“: this includes work on the ‘non-financial sector’, that is supposed to be able to use the concepts that the EBA has developed for the financial sector [1].
• “State of play and way forward – Building of AMLA (business, administration)” mentioned the digital tools of the AMLA [2]. The AMLA will use the website and linkedin for communication. The sections on recruitment address the role of member states and specific expertise [3], but not the importance of adequate knowledge on the non-financial sector and the specific legislation (differing from country to country) to those obliged entities.
• In “AMLA Work Programme 2025 – Supervisory pillar” attention is paid to the differences between financial and non-financial sector [4] and to the risk assessment methodologies: “Regarding risk assessment methodologies in general, the point was made that member states were evaluated against different methodologies from FATF, MONEYVAL, and the EBA, and this represented a challenge which AMLA should help address.“

Transaction monitoring and the use of digital tools was discussed during the meeting [5].

It will be interesting to see whether the AMLA understands enough about the non-financial sector and can ensure that financial sector rules are not blindly transferred to companies that do not understand them.

Recently the AMLA published the Work Programme for 2025.

Notes

[1] “Regarding the non-financial sector, the Commission referred to the work conducted within the dedicated expert group created to work on all the Level 2 mandates (risk assessment, CDD and administrative sanctions) that the EBA has also been developing for the financial sector. The expert group is scheduled to expire in October this year.”

[2] “The IT building block addressed three types of requirements. The need for a digital workspace, based on the Cloud, was deemed completed, thanks to the support of the Commission DG DIGIT. For applications to run document management, HR and budget processes, AMLA was also expected to use European Commission tools. By the end of October, AMLA was expected to be equipped with the necessary tools to operate efficiently. Regarding IT business solutions geared to the specific needs of AMLA, mid-term and long-term reflections had been initiated. These solutions aim at equipping AMLA with automated data gathering and analytical capabilities leveraging the advanced technology, including AI. Important elements were still missing, notably the sources and exact data sets that will feed the databases, the details of the risk methodology, and, importantly, the views of the incoming Executive Board e.g. on sensitive matters such as data governance.” and “Finally, in relation to ICT, some members expected AMLA to clarify what tools it expects to use and for what purposes, since these decisions will also have a huge impact on the NCAs.”

[3] “On recruitment, the Chair recalled her motto and support to diversity in terms of gender, geographical balance, and skills (ie having not only AML experts, but also statisticians, mathematicians, macroeconomists, crypto experts, payment experts, etc…); she also mentioned that most of the recruitments will be opened to the public, with vacancies through the EU agencies channel only used exceptionally.”

[4] “A member of the Risk and Measures Team (…) emphasising the difficulty of accommodating basic concepts, that were quite familiar in the financial sector, to the non-financial industry, such as the concept of business relationship. Another challenge was to adapt the business wide risk assessment to the size of the obliged entities, without losing any substance.“. Strange that this would be the only area of concern.

[5] “Discussion: Almost all members who took the floor emphasized the importance of technology as a game changer reshaping not only the financial sector, but also the way criminals operate, as well as the way supervisors should conduct their activities. For some there was a unique opportunity for AMLA to harness its full potential. This did not mean starting from scratch as some tools already existed (for instance in terms of transaction monitoring) and one first step could be about improving the interlinking across member states. The importance taken by the simplification agenda, and the need to reach out to the private sector, were also raised.
The Chair concluded by confirming the top priority status of technology, as well as the importance of a risk-based approach (including a macro-perspective) and proportionality in AML/CFT supervision, also to ensure that private sector compliance costs are duly taken into account. She recalled that AMLA will apply better regulation principles as envisaged in the AMLA regulation, including impact analyses and public consultations that will allow to assess costs and benefits. However, she also recalled that the overall aim of the AML package is to ensure that the framework is robust, uniform and effective, and that AMLA’s work will have to find the right balance to achieve these goals.“