2026年欧洲反金融犯罪行政优先事项

Contents Executive summary3 Executive summary As European Anti-Financial Crime (AFC) executives look toward 2026, the challenges havefundamentally evolved. The question is no longer whether institutions understand regulatoryexpectations, emerging threats or new technologies. It is whether they canexecute at scale, The AFC landscape is being reshaped by a powerful convergence of structural forces. Theestablishment of the Anti-Money Laundering Authority (AMLA) is accelerating regulatoryconsolidation and supervisory comparability across Europe. At the same time, cost pressure on Against this backdrop, AFC executives are being asked to do far more than prevent financialcrime. They muststreamline and standardize controls across jurisdictions, contain and justifyAFC spend, shift from reactive to proactive risk management, and collaborate beyond Drawing on our work with European financial institutions and ongoing dialoguewithAFC leaders, four recurrent themes emerge for 2026. Institutions will need to pivotfrom: •Fragmented compliance to execution and simplification excellence under AMLR andAMLA•Cost control to value discipline and measurable Return on Investment(ROI)•Isolated AI pilots focused on task automation to developing a comprehensive AI AFCstrategy leverage for instance agentic AI as an end-to-end processorchestrator Combined, these priorities signal a broader inflection point for the AFC function. Institutionsthat continue to layer new requirements onto fragmented legacy models will face rising cost,complexity and supervisory friction. Those that act early, aligning policy, data, technology, To navigate 2026 and beyond, AFC executives will need a clear strategic response toeachof these themes. This needs to be grounded in execution excellence, measurableoutcomes, Leverage the new AML packageas a simplification engine From fragmented compliance to group wide,scalable execution The new EU AML package marks a structural shift in the EU’s AML/CFT regulation and supervision.Beyond new regulatory technical standards, its real impact will be felt throughmore consistentrules, clearer expectations across the EU and greater supervisory comparability. Well prepared With the implementation of the new EU AML package, the EU movestoward: •A directly applicable AML rulebook (AMLR) replacing 27 divergent nationaltranspositions•A single supervisory center of gravity, with AMLA setting methodologies and directlysupervising the riskiest cross-border institutions through joint supervisoryteams If approached strategically, this consolidation can be acatalyst for institutions to harmonizeand streamline AML/CFT operating models at scale, reducing duplication, national bespokesolutions and fragmented supervisory interactions. Key enablers include harmonized CDD and Streamlining, however, is not a given. Institutions that treat the EU AML package purelyasa compliance milestone risk entrenching fragmentation and carrying forward legacy divergence.Institutions that act early will be able to leverage the package not only to meet higher supervisory What AFC executives should prioritize in 2026 assessment, model inventory, back testing, QA/IA outcomes to serve both AMLAand National Competent Authorities (NCAs), so supervisors see one coherent crossbordernarrative change control for AMLR RTS/guidelines and FIU templates, and a standard KRI/KPI packacross all EUentities governed local-variancelayer governance to AMLR methodologies, calibrate cross-border scenarios once and applyacross EUbooks 5Centrally standardize data, including data quality controls, and technology by mappingKYC/TM/Sanctions data models to AMLR fields, building once for the EU FIU reportingtemplate for reuse across Member States and rationalizing case management workflowsfor joint supervisoryteams Manage AFC cost withoutdiluting control effectiveness From cost center to value discipline Cost control has moved from a background constraint to a central strategic priorityforAFC leaders in Europe. Institutions are under pressure to contain bank-wide compliance costsacross all lines of defense while maintaining robust controls, as regulatory expectations, AFC spend need to continue to rise, with technology investment and staffing as dominantcost drivers given the necessary investments into new detection techniques and improveinvestigations processes. Compliance costs are further exacerbated by high false positiverates, fragmented data architectures, and manual investigation processes that consume Leading institutions are responding by engineering efficiency at scale, not by cutting corecontrols. They are enhancing processes with AI and richer data capabilities to reduce falsepositives, automating low-risk, repeatable tasks to free expert capacity and right-shoring What AFC executives should prioritize in 2026 technology investments are used to remove noise and expert time is concentrated onhigh-risk, high-valuetasks Reimagine AFC as proactiv