The report examines the functioning of AML/CFT colleges, which bring together supervisory authorities to combat financial crime. It highlights that while the structure of the colleges has remained stable, limited progress has been made in implementing a risk-based approach. The report covers the period from January 1, 2024, to May 31, 2025, and emphasizes the importance of information exchange among supervisors.
This report, entitled “Report on the functioning of AML/CFT colleges in 2024 and 2025”, was published in October 2025 by the European Banking Authority (EBA). It covers the period from 1 January 2024 to 31 May 2025 and addresses the functioning of anti-money laundering and counter-terrorist financing (AML/CFT) colleges within the European Union. The scope includes 258 colleges supervising financial institutions operating in at least three Member States, focusing on information exchange, cooperation among competent authorities, and implementation of best practices in AML/CFT supervision.
The report addresses the functioning of AML/CFT colleges, permanent structures bringing together supervisory authorities responsible for combating money laundering and terrorist financing for cross-border financial institutions operating in at least three Member States. These colleges aim to facilitate information exchange and cooperation to improve supervision and combat financial crime. During the covered period, the EBA actively monitored nine colleges and collected data on 258 colleges. The college framework remained stable, with a total number similar to 2023, steady participation of financial intelligence units (FIUs) and prudential supervisors, and a slight increase in third-country observers. However, two previously identified priorities have seen little progress: the application of a risk-based approach to organise colleges, which remains insufficient, limiting effective allocation of human resources and participation; and the holding of systematic and meaningful discussions on common approaches, which remain rare, preventing identification and coordinated management of common risks. From January 2026, responsibility for AML/CFT college supervision will be transferred to the European Anti-Money Laundering Authority (AMLA), this report being the last published by the EBA. The conclusions call on AMLA to take these findings into account to strengthen the future effectiveness of colleges.
The report falls within the legal framework defined by Article 57a(4) of Directive (EU) 2015/849 (AMLD), which requires competent authorities to cooperate closely in AML/CFT supervision of cross-border financial institutions. AML/CFT colleges, introduced in 2020, are permanent structures aimed at facilitating this cooperation. The EBA’s mission is to monitor their functioning, a task it has performed since the colleges’ creation. This document aims to provide an updated overview of these colleges between January 2024 and May 2025, to assess progress on previous recommendations, and to identify persistent challenges. It also serves as a transition before the transfer of responsibilities to AMLA in 2026. The report is based on data collected via questionnaires, the EuReCA database, ML/TF risk assessments, and direct observation of certain colleges. Limitations notably concern the covered period and the fact that some colleges have not yet been established or fully operational.
General functioning of colleges: As of 31 May 2025, 258 AML/CFT colleges were active in the EU, slightly fewer than in December 2023 (264), due to mergers or closures. Nearly half concern credit institutions, the others mainly covering investment firms, collective investment undertakings, and payment institutions. College size varies from 1 to 32 members, the majority (55%) having between 3 and 5 members. FIU participation (58%) and prudential supervisors (71%) is stable, while the number of third-country observers has slightly increased (57 colleges versus 41 in 2023), although their presence remains limited due to the lack of equivalence assessments of confidentiality regimes. Meeting frequency is mostly annual (45%), with variations ranging up to one meeting every three years or written communication only. Participation of supervised entities as “guests” is common (58%), often to present their AML/CFT arrangements.
Role and activities of the EBA: The EBA ensured dual supervision, general (annual data collection via notifications and questionnaires) and active (direct participation in meetings of certain colleges selected according to risk criteria). Between 2024 and May 2025, the EBA monitored 258 colleges and attended 11 meetings of 9 colleges. It observed an improvement in organisation and quality of exchanges in actively monitored colleges, with more focused discussions and effective leadership by lead supervisors. However, gaps remain, notably the absence of systematic discussions on common risks and lack of preparation by some participants. The EBA also supported the creation and development of colleges, notably by assessing equivalence of third countries (Australia, Montenegro), organising training, and facilitating information exchange via the EuReCA database.
Implementation of key actions: Six priority actions were defined by the EBA to improve college functioning. Action 1 (finalise structural elements, cooperation agreements, participation) is largely implemented, despite occasional difficulties obtaining signatures or participation from some members. Action 2 (improve quality of discussions) is also largely implemented with good practices such as use of structured materials and focus of presentations on specific risks. Action 3 (promote continuous cooperation) is largely implemented, with ad hoc meetings triggered by significant events. Conversely, Action 4 (apply a risk-based approach to organise meetings) is only partially implemented: meeting frequency is often set without full consideration of risk level, leading to inefficient resource allocation. Action 5 (identify needs for common approaches or joint actions) is also partially implemented, most colleges not sufficiently discussing common risks or coordinated measures. Finally, Action 6 (strengthen convergence of supervisory practices) is not implemented, recommended topics not being addressed during meetings.
Findings: The number of AML/CFT colleges is stable with 258 active colleges in May 2025. FIU and prudential supervisor participation is stable, while third-country observer presence slightly increases. The majority of colleges meet once a year, with frequent participation of supervised entities. The EBA noted an improvement in organisation and quality of exchanges in actively monitored colleges.
Hypotheses: The improvement in exchange quality is linked to implementation of best practices recommended by the EBA. The low participation of third countries is partly due to the absence of equivalence assessments of confidentiality regimes.
Interpretations: Despite progress, insufficient application of a risk-based approach to organise colleges limits overall effectiveness, notably regarding resource allocation and participation. The lack of systematic discussions on common risks prevents coordinated and coherent supervision at European level.
Uncertainties: The report does not detail precise reasons for lack of application of certain recommendations, nor specific obstacles encountered by competent authorities. The real impact of these gaps on prevention of money laundering and terrorist financing remains to be assessed over time.
The EBA concludes that AML/CFT colleges are now effective tools for exchanging relevant information among competent authorities. However, two key actions remain insufficiently implemented: applying a risk-based approach to organise meetings (frequency and modalities adapted to risks and institution characteristics) and systematically identifying common risks to coordinate actions. These gaps limit colleges’ capacity to effectively supervise cross-border financial institutions. The EBA therefore recommends competent authorities focus their efforts on these two points before the entry into force of the new AMLD6 framework in July 2027. From 1 January 2026, AMLA will take over from the EBA for college supervision and must ensure to strengthen their effectiveness based on the findings and recommendations of this report.
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