This report presents the findings of an evaluation of the effectiveness of national competent authorities (NCAs) in combating money laundering and terrorist financing in the EU banking sector between 2018 and 2024. NCAs implemented AML/CFT supervisory strategies and plans while enhancing their supervisory manuals for a more consistent approach. Significant efforts were made to strengthen national and international…
This final report of the European Banking Authority (EBA), published in October 2025, presents a review of the approaches of national competent authorities (NCAs) regarding anti-money laundering and counter-terrorist financing (AML/CFT) in the banking sector of the European Union and the European Economic Area (EU/EEA). It covers AML/CFT supervisory activities carried out between 2018 and 2024 by 40 NCAs, including the assessment of their strategies, plans, manuals and supervisory tools as well as their national and international cooperation. The report relies on qualitative evaluation and monitoring methodologies, integrating bilateral exchanges and questionnaires with NCAs, focusing on AML/CFT supervision and cooperation, in preparation for the transition to the new European AML/CFT regulatory framework and the future role of the European Anti-Money Laundering Authority (AMLA) (p. 1-9).
The report addresses the effectiveness of NCAs' approaches in combating money laundering and terrorist financing (ML/TF) in the European banking sector. This topic is crucial as several major cases revealed weaknesses in the application of AML/CFT frameworks, requiring improvement in supervisory practices. The main findings show that most NCAs have implemented AML/CFT supervisory strategies and plans, strengthened their manuals and used their supervisory tools more strategically. Regarding cooperation, significant progress has been made at the national level, notably with financial intelligence units (FIUs) and tax authorities, as well as internationally through AML/CFT colleges and bilateral exchanges. However, challenges remain, including staff shortages, budget constraints and resource reallocations related to preparing the new AML/CFT framework and sanctions regimes. Despite these difficulties, the overall effectiveness of AML/CFT supervision and cooperation has improved, facilitating the implementation of the new framework and the work of AMLA. The report concludes this evaluation cycle by providing an updated basis for future indirect supervision by AMLA (p. 4, 20-21).
The document was prepared in response to high-profile money laundering cases involving European banks, which highlighted deficiencies in the effective application of the EU AML/CFT legal framework. Since 2018, the EBA has conducted qualitative implementation reviews of NCAs’ practices in all EU/EEA Member States, covering three years of supervisory activities. The objective is to identify areas for improvement, provide bilateral feedback to NCAs and enhance the consistency and effectiveness of AML/CFT supervision. The scope covers strategies, plans, manuals, supervisory tools as well as national and international cooperation. Limitations include the absence of quantitative evaluation or rating, consideration of national specificities and distinction from other international assessments (FATF, Moneyval, IMF) which may differ in methodology and scope (p. 5-9).
AML/CFT Supervision:
- Supervisory strategies: The majority of NCAs now have an AML/CFT strategy, often absent or insufficient previously. 71% of NCAs without a strategy at the time of the review have adopted one since, although 13% are still in progress or without a strategy. Strategies have been improved for alignment with EBA guidelines, including adequate sector coverage, adapted activity cycles and targeted use of supervisory tools (p. 9-10).
- Supervisory plans: Almost all NCAs have an annual or biannual plan detailing the implementation of their strategy, with better integration of risk assessments, coordination with prudential supervisors and inclusion of on-site and off-site activities. 75% of NCAs without an initial plan have created one, but 36% have not yet fully met recommendations (p. 10-11).
- Supervision manuals: All NCAs have a manual or are preparing one, with 81% of manuals revised to include tool selection criteria, methods for assessing AML/CFT control effectiveness, and cooperation frameworks. However, 25% have not yet fully addressed the recommendations (p. 11-12).
- Supervisory tools: Most NCAs now use their tools more strategically, including proportionate follow-up measures, use of external parties, and improved feedback to the sector. 90% of NCAs have enhanced the intrusiveness of their supervision (p. 12-14).
Cooperation:
- Domestic cooperation between NCAs: In states with multiple NCAs supervising banks, coordination has improved via MoUs, clear task allocation and regular meetings, although some states still require progress (p. 14-15).
- Cooperation with FIUs, tax authorities and law enforcement: The majority of NCAs have formalized agreements with these entities, but nearly half do not fully use these cooperation channels. Measures include MoUs, dedicated contact points, regular exchanges and IT tools facilitating communication (p. 15-16).
- Cooperation with prudential supervisors: Despite initial challenges related to lack of specific training, 57% of NCAs have improved their cooperation mechanisms via MoUs, regular meetings and targeted training programs, although some NCAs remain behind (p. 16-17).
- International cooperation: NCAs have strengthened bilateral cooperation and via AML/CFT colleges, which have become effective tools for information exchange. However, cooperation with third-country authorities remains limited, with only 55% of NCAs having improved this aspect, and efforts are needed to strengthen MoUs and supervision of foreign branches (p. 17-19).
Findings:
- 71% of NCAs without an AML/CFT strategy in 2018-2024 have adopted one since.
- 75% of NCAs without an AML/CFT supervision plan have implemented one.
- 81% of NCAs have revised their supervision manual to make it more comprehensive.
- 90% of NCAs have improved the strategic use and intrusiveness of their supervisory tools.
- Domestic and international cooperation strengthened, notably via MoUs and AML/CFT colleges.
Hypotheses and interpretations:
- Progress is linked to the direct impact of EBA feedback and recommendations.
- Recently assessed NCAs have not yet finalized all improvements.
- Resource constraints and increasing risk complexity influence the pace of reforms.
Uncertainties:
- The actual effectiveness of new strategies and tools in preventing ML/TF remains to be measured.
- International cooperation with third countries remains a weak point requiring increased monitoring.
- The impact of the new AML/CFT framework and AMLA’s role on NCAs’ practices remains to be observed (p. 9-20).
NCAs face several challenges limiting their ability to reform quickly and effectively:
- Multiple external assessments (FATF, Moneyval, IMF) with divergent methodologies, creating pressure on resources and complex prioritizations.
- The establishment and strengthening of national cooperation, notably among several authorities, is a long and costly process.
- Significant changes in the European AML/CFT legal and institutional framework require considerable NCA commitment, sometimes delaying internal reforms.
- Shortages of qualified staff and budget constraints hinder supervision, especially given the increasing complexity of risks (e.g. crypto-asset related services).
- Geopolitical uncertainty and the increase of EU and international sanctions regimes complicate supervision and mobilize additional resources without corresponding staff increases.
These limits may slow the full implementation of recommendations and affect the quality of AML/CFT supervision (p. 20).
The EBA concludes that NCAs have made significant progress in adopting a risk-based approach to AML/CFT supervision, with dedicated strategies, plans and manuals, as well as strengthened cooperation at national and international levels. The EBA’s work has been instrumental in these advances.
For the future, under AMLA’s responsibility, several priorities are identified:
- Supervisory strategies: clarify the consideration of sectoral ML/TF risks and ensure adequate coverage.
- Supervisory planning: develop comprehensive plans with measurable indicators to monitor their execution.
- Supervisory manuals: detail available tools, their appropriate use, and guide supervisors in assessing AML/CFT controls, including adapting the level of intrusiveness.
- Domestic cooperation: strengthen collaboration between prudential and AML/CFT supervision, formalize exchanges with FIUs and tax authorities via MoUs, regular meetings and structured processes.
- International cooperation: consolidate MoUs with non-EU authorities, strengthen supervision of foreign branches, and deepen understanding of ML/TF risks of international banking groups.
These recommendations aim to ensure more effective and consistent AML/CFT supervision within the new European framework (p. 21-22).
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