AMLA’s 2025 Roadshow reveals a striking reality: despite national differences, the same AML/CFT challenges keep emerging across all 27 EU Member States. From fragmented supervision and limited resources to technological gaps and regulatory complexity, these recurring obstacles point to deeper structural issues. In this article, we explore the key challenges identified by stakeholders and what they mean for the future of Europe’s AML/CFT framework.
The same obstacles, in country after country.
One of the more sobering findings of AMLA's 2025 Roadshow is not that every Member State faces different problems, but that they largely face the same ones. That recurrence across all 27 countries points to challenges that are structural, not national. The report groups them into three categories: legacy challenges inherited from the old framework, emerging challenges driven by technology and geopolitics, and challenges tied to regulatory complexity itself.
Legacy challenge 1: a fragmented supervisory and intelligence landscape
The most pervasive issue is fragmentation, rooted in a framework that, until now, relied on national transposition. In practice, this means:
● Divergent supervisory methodologies across Member States, leading to inconsistent expectations for obliged entities operating cross-border and, in some cases, room for jurisdiction shopping.
● Overlapping mandates within countries, especially in the non-financial sector, where supervisory responsibility is often spread across multiple bodies.
● Uneven cross-border cooperation, with FIUs reporting that differences in analytical capability and resourcing affect the speed and usability of financial intelligence exchanged between countries.
Legacy challenge 2: low AML/CFT maturity in the non-financial sector
Smaller firms and sole practitioners were repeatedly described as having limited awareness of their obligations and limited tools to act on them even when they are aware. This came up in particular in real estate, accountancy, notarial services, and high-value goods trading. One finding stood out: low volumes of suspicious transaction reports from this sector were sometimes read by practitioners as proof of low risk, while supervisors and FIUs read the exact same pattern as evidence of under-detection.
Legacy challenge 3: resource constraints across every sector
Public supervisors cited limited access to specialist expertise in fast-moving areas such as crypto-assets. Non-financial authorities described trying to oversee large, heterogeneous populations of obliged entities with very small dedicated teams. FIUs reported rising caseloads without matching growth in staff or technology. In the private sector, financial institutions face escalating compliance costs, while small non-financial firms often see AML/CFT as one obligation among many that collectively exceed what they can realistically manage.
Emerging challenge: the technology gap is widening in real time
The same technological shifts driving new risks are also straining the capacity to supervise and comply with them. Supervisors struggle to procure, govern, and staff the right tools. FIUs face interoperability and automation gaps just as report volumes rise. For smaller non-financial firms, digital compliance solutions are often seen as too costly or complex to integrate. That divide risks making compliance disproportionately burdensome for exactly the entities least equipped to absorb it.
Regulatory complexity: AML/CFT versus GDPR
One of the most operationally significant tensions raised throughout the Roadshow was the friction between AML/CFT monitoring obligations and GDPR requirements around data sharing and retention. Both financial institutions and FIUs flagged this: complying with one framework can create a risk of breaching the other. Clearer guidance on how the two frameworks interact was one of the most consistent asks directed at AMLA.
On top of this, stakeholders flagged the compressed timeline for implementing Level 1 requirements, alongside a substantial body of Regulatory and Implementing Technical Standards still to concerned about their ability to prepare systems and governance in time.
A coherent, mutually reinforcing picture
None of these challenges sit in isolation. Fragmented starting points mean a common rulebook lands on very uneven ground. Resource constraints increase the risk that obligations become a box-ticking exercise rather than genuine risk management. Time pressure and the pace of technological change compound both. AMLA itself acknowledges that neither the reform nor its own establishment can resolve all of this at once, it is still a young authority building its capacity over time, within a mandate defined by the co-legislators.
The question the report poses is not whether these challenges can be eliminated, but where targeted action can make the biggest difference. In the final article of this series, we look at the concrete opportunities and early steps AMLA is already taking in response.
