Financial crime is evolving, and so are the risks facing Europe's AML/CFT framework. From AI-driven fraud and crypto assets to instant payments, cash-based laundering and sanctions evasion, AMLA's Roadshow reveals six key risk areas shared across EU Member States. This article explores the emerging threats, persistent vulnerabilities and growing expectations for a coordinated European response.
The ML/TF risk landscape is moving faster than the rules designed to contain it.
Across all 27 Member States, AMLA's Roadshow found a striking degree of agreement on where the real risks lie. Long-standing typologies have not disappeared, but they now sit alongside faster-moving threats shaped by technology and geopolitics. Six risk areas stood out.
Fraud: the blurring line with money laundering
Fraud emerged as one of the fastest-growing categories of criminal activity, and the private sector in particular flagged how thin the line has become between fraud and laundering. Illicit proceeds from fraud now move into laundering channels almost immediately, which is pushing some institutions to merge their fraud and AML functions into a single department.
Key drivers behind this shift:
● AI-generated synthetic media, including deepfakes, enabling impersonation and identity fraud at scale.
● Remote onboarding, which opens an additional vector for identity abuse.
● Instant payments, which compress the window in which institutions can intervene before funds disappear.
Stakeholders also pointed out that fighting fraud effectively requires looking beyond financial services to telecoms, internet platforms, and social media, where fraud can be prevented at source.
Crypto assets: implementation now, not rule-setting
As MiCA moves from rule-setting into supervision of CASPs, stakeholders across most Member States raised concerns about the consistency of supervisory approaches. Structural vulnerabilities include limited transparency on beneficial ownership, the speed of crypto transfers, and uneven supervisory experience across the EU. Specialist blockchain analytics tools were flagged as costly, since capability remains concentrated among a small number of providers.
Cross-border transactions and instant payments
Instant payments now move funds across borders in real time, 24 hours a day. That fundamentally shortens the window in which supervisors and institutions can detect and act on suspicious activity. Traditional end-of-day batch monitoring is increasingly out of step with this reality. That pressure will only grow as the EU Instant Payments Regulation accelerates the roll-out of instant transfers across the Union.
Cash and real estate: old risks, still very much alive
Cash-based laundering has not been displaced by digitalisation. It simply coexists with it. Real estate remains a preferred vehicle for laundering large sums, thanks to its ability to absorb funds securely while offering economic returns. Opaque ownership structures and unclear asset valuation add to that. Notaries involved in transactions, where required, were seen as a mitigating factor. AML/CFT maturity across real estate intermediaries still varies significantly between Member States.
Online and illegal gambling
Beyond the well-known cash risks in traditional gambling, online and illegal platforms operating outside EU jurisdictions emerged as a growing concern. The lack of harmonised rules across Member States was described as a structural vulnerability, creating room for regulatory arbitrage and uneven conditions for licensed operators. This is an area where stakeholders explicitly want AMLA to lead on harmonisation.
Geopolitical shifts and sanctions
Since Russia's full-scale invasion of Ukraine in 2022, sanctions circumvention has become a much more prominent supervisory concern, particularly in Member States with heightened geopolitical exposure. Large financial institutions have generally invested in the compliance infrastructure to manage this, but parts of the non-financial sector reported lower awareness of sanctions obligations. That capacity gap can become a vulnerability in itself.
What stakeholders expect from AMLA
Across all six areas, the same message came back: national authorities cannot tackle fast-moving, cross-border risks alone. Stakeholders see AMLA's added value in aggregating typologies at EU level, supporting a coherent cross-border response, and helping close the gap between institutions that are well-resourced and those that are not.
In the next article, we turn to the structural challenges behind these risks: the legacy fragmentation, resource constraints, and regulatory tensions that make an effective response harder than it should be.
