Anti-money laundering
While the ECB’s supervisory tasks explicitly exclude the supervision of anti-money laundering and countering the financing of terrorism (AML/CFT), money laundering and terrorist financing can pose significant risks to the safety and soundness of banks. We therefore take such risks into account in our prudential supervision.
The Capital Requirements Directive (CRD) clarifies the link between prudential supervision and AML/CFT supervision and requires prudential supervisors to act on AML/CFT information. In particular, the CRD introduces an explicit cooperation obligation between prudential supervisors, AML/CFT supervisors and financial intelligence units. This facilitates efficient and effective supervision, and coordinated supervisory action where necessary.
In 2024 the Council of the European Union adopted a new AML/CFT legislative package which harmonises EU AML/CFT rules for the first time to protect citizens and the EU’s financial system against money laundering and terrorist financing. The package includes a regulation establishing a new EU anti-money laundering authority (the Authority for Anti-Money Laundering and Countering the Financing of Terrorism – AMLA ) which will have direct and indirect supervisory powers over high-risk obliged entities in the financial sector.
In June 2025 the ECB concluded a Memorandum of Understanding with AMLA defining how we will work together. It sets out principles for information exchange and regular collaboration on policies and standards.
Supervision of financial institutions’ compliance with AML/CFT requirements remains an exclusive competence of AML/CFT authorities. However, concerns about money laundering or terrorist financing – especially concerns stemming from AMLA and national AML/CFT authorities’ assessments of risks associated with individual institutions – are considered in prudential supervisory processes, in particular:
in authorisation and in fit and proper assessments, the extent to which the applicant’s business model, the proposed risk management systems and controls, and the suitability of its shareholders, members, management body, senior management and key function holders give rise to money laundering and terrorist financing risks;
as part of ongoing supervision and the Supervisory Review and Evaluation Process (SREP), in the review of risks, when money laundering and terrorist financing risks are connected to business models, credit operations, governance and internal risk management;
when taking any prudential administrative measures, particularly the imposition of penalties or proceeding to a withdrawal of authorisation process, thereby ensuring that AML/CFT-related weaknesses with a prudential impact are taken into account in the application of prudential supervisory measures and powers to alleviate prudential concerns.
Against this background, close cooperation and the exchange of information between prudential supervisors, AMLA and national AML/CFT authorities remain essential. This is because prudential supervisors use information held by AML/CFT authorities in their supervisory processes and AML/CFT supervisors use information from prudential supervisors to inform their approach to the AML/CFT supervision of institutions.
Increased regulatory and supervisory focus alone will not be enough to successfully fight money laundering and terrorist financing in the financial sector. It is, first and foremost, the institutions who need to ensure that they are not used for these purposes and that AML/CFT issues attract proper management attention.
To do this, institutions must ensure at all times that members of their management body and senior management are of sufficiently good repute and possess sufficient knowledge, skills and experience to perform their duties. Institutions are also responsible for ensuring that their governance and risk management are adequate and enable them to identify, assess and manage the risks to which they are (or may be) exposed, including money laundering and terrorist financing risks.