2026年欧洲反金融犯罪行政优先事项

Contents Executive summary3 Leverage the new AML package as a simplificationengine:From fragmented compliance to group wide, scalable execution4 Manage AFC cost without diluting controleffectiveness:From cost center to value discipline6 Reimagine AFC as proactive andcontinuous:From AI pilots to agentic AI8 Leverage public-private partnerships and utilities as forcemultipliers:From siloed defenses to collective intelligence11 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,simplify fragmented operating models and demonstrate tangible value from sustainedAFC investment. 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 onAFC and compliance functions continues to intensify, driven by rising data volumes, persistentfalse positive levels and heightened expectations on effectiveness. In parallel, AI and advancedanalytics are maturing rapidly and showing potential, while financial crime threats themselvesare becoming more digital, networked and cross-border, outpacing traditional, reactivecontrolframeworks. 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 beyondinstitutional boundaries, all while maintaining credibility with increasingly data-drivensupervisors and delivery of a seamless, low friction customerexperience. 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•Siloed institutional defenses to collective intelligence enabled by public-private partnershipsand industryutilities 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,governance and collaboration around a more harmonized European framework can repositionAFC from a defensive necessity to a scalable, value enablingcapability. 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,and a fundamentally different approach to how financial crime is managed acrossEurope. 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 preparedinstitutions will be able to use this shift not just to comply, but as a catalyst to simplify AML/CFTprocesses and accelerateefficiency. 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•A harmonized supervisory methodology for inherent/residual risk exposures, appliedconsistentlyEU-wide 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 andEDD requirements, a single beneficial ownership threshold, standardized suspicious reportingtemplates, and improved EU-wide data access (e.g., beneficial ownership registers). At the sametime, AMLA will raise expectations around ownership-based screening, data quality and theability to evidence effectiveness across jurisdictions and businesslines. Streamlining, however, is not a given. Institutions that treat the EU AML package purelyasa compliance milestone risk entrenching fragmentation and carrying forward legacy divergence.Institu