The European Banking Authority’s final assessment of the bloc’s anti-money laundering and countering the financing of terrorism colleges reveals both quiet progress and a worrying inertia at the heart of cross-border supervision. As the oversight baton passes from the EBA to the new Anti-Money Laundering Authority, the findings underscore an uncomfortable truth: information exchange across borders remains too slow, too fragmented, and too procedural to keep pace with modern laundering networks.
The report covering 2024 and the first half of 2025 paints a detailed picture of a structure that works on paper yet struggles to adapt to risk in practice. Two years before the new EU AML framework takes effect, the system designed to connect supervisors across Member States remains unevenly used and, at times, underpowered.
Table of Contents
The functioning of AML/CFT colleges
Anti-money laundering and counter-terrorist financing colleges were conceived as permanent cooperation mechanisms, each bringing together the national authorities supervising a single cross-border financial group. As of mid-2025, 258 such colleges exist across the Union, involving banks, investment firms, funds, insurers, and payment institutions. Each is meant to be a hub for timely data exchange and coordinated supervision.
Yet, the European Banking Authority found that most colleges still operate as compliance checklists rather than dynamic coordination forums. Almost half are centered on banks, with the rest spread across non-bank sectors, but participation from financial intelligence units and prudential supervisors remains inconsistent. Around 58 percent include the FIU, and 71 percent have prudential supervisors, numbers unchanged from the previous year.
The goal was clear when the structure was codified in the fifth and sixth Anti-Money Laundering Directives: enable joint scrutiny of cross-border institutions so that no single supervisor misses red flags in another jurisdiction. However, data from the 2025 report show that nearly one in five colleges still lacks signed cooperation agreements among all members. Some fail to convene meetings frequently enough to respond to emerging risks. Others meet too often without differentiating between low-risk and high-risk groups, creating a misallocation of supervisory resources.
Only 19 percent of colleges have adopted a common approach or taken joint actions, such as coordinated inspections or harmonized remediation measures. In an environment where laundered funds move digitally across borders within hours, such coordination rates remain alarmingly low.
Applying the risk-based approach to AML supervision
The EBA’s persistent concern since 2022 has been the limited adoption of the risk-based approach across the college system. Although supervisors are required under EU law to tailor the frequency and depth of cooperation to the level of money laundering and terrorist financing risk presented by an institution, most still use uniform annual schedules.
The report notes that some authorities have introduced tiered frequencies—annual meetings for high-risk entities, biennial or triennial for lower-risk ones—but this remains the exception. In many cases, even low-risk institutions absorb disproportionate attention, while high-risk cross-border groups receive insufficient scrutiny. The outcome is paradoxical: abundant administrative activity without a proportionate focus on real laundering threats.
This imbalance also affects participation quality. Some authorities send representatives unfamiliar with recent supervisory actions, limiting meaningful debate. Others fail to share structured information in advance, which undermines the entire purpose of collective intelligence.
Applying the risk-based approach to colleges is not merely a procedural reform—it is the linchpin of Europe’s capacity to detect transnational laundering schemes. Without it, even the most sophisticated legislative framework becomes an exercise in compliance rather than prevention.
The report highlights that the problem is not legislative but cultural: supervisors tend to view the college meetings as events rather than ongoing intelligence networks. The challenge for AMLA, once it assumes responsibility in 2026, will be to instill a new operational discipline where data exchange and joint analysis happen continuously, not periodically.
The shift from EBA to AMLA oversight
January 2026 marks a historic handover. After five years of stewardship, the European Banking Authority will transfer its AML/CFT monitoring role to the new EU Anti-Money Laundering Authority. This institutional transition is more than administrative—it represents the consolidation of fragmented supervisory coordination under a single EU body.
The EBA’s final report emphasizes that the college model will remain central under the upcoming legislative package that becomes applicable in 2027. AMLA will inherit both the strengths and weaknesses of the system. Among its first tasks will be to harmonize how colleges operate, ensure consistent application of the risk-based approach, and expand participation from third-country observers.
The inclusion of external authorities has been modest. Only 57 colleges have admitted at least one non-EU observer, such as AUSTRAC or the Central Bank of Montenegro, following EBA equivalence assessments. Yet, the global nature of financial flows demands broader engagement. Without regular input from jurisdictions that handle the offshore or correspondent activities of EU financial institutions, major risk gaps persist.
Under AMLA, colleges are expected to become not only coordination platforms but active supervisory instruments. This implies real-time data sharing through systems like EuReCA—the central database for material AML/CFT weaknesses—and the ability to trigger joint inspections or enforcement actions. The EBA’s previous recommendations on standard templates, topic-specific sessions, and targeted firm participation could serve as a baseline, but AMLA will need to go further by embedding digital supervision tools and analytical dashboards that can process cross-border anomalies at scale.
The upcoming centralization will test whether the EU can translate years of fragmented dialogue into operational coherence. The success of AMLA’s model will depend on whether colleges evolve from discussion forums into intelligence-driven supervision networks capable of detecting typologies before they crystallize into scandals.
Coordinated supervision and the road ahead
The 2025 report underscores a paradox: the European AML architecture is structurally sound yet functionally fragile. Colleges exist, meetings are held, and data is shared, but common approaches remain rare. The reason lies in inconsistent prioritization and a reluctance to confront supervisory asymmetries head-on.
Most colleges continue to rely on national frameworks when assessing institutions’ AML systems, even when those institutions operate under a unified EU license. This creates fragmented risk assessments and divergent remediation measures. A bank could be flagged as high-risk in one jurisdiction and low-risk in another, despite identical group-wide processes. Such inconsistencies hinder the EU’s ability to act as a single financial area against money laundering.
The EBA’s evaluation also reveals that some supervisors treat colleges as a compliance burden rather than an analytical opportunity. Invitations to third-country observers, for instance, are sometimes delayed not for legal reasons but due to bureaucratic caution. The resulting exclusion weakens collective understanding of cross-border typologies, especially in correspondent banking and digital asset transfers.
As AMLA takes over, it faces a dual mandate: streamline procedures while reinforcing substance. Achieving this requires embedding the risk-based approach into the digital workflows of supervisors, linking EuReCA data with real-time suspicious transaction reports, and standardizing templates for thematic reviews.
The vision is for AML/CFT colleges to function as Europe’s early-warning system for financial crime—a network capable of identifying patterns of abuse that no single national authority could detect alone. To reach that point, the EU’s supervisory community must treat cooperation not as a statutory obligation but as a shared defense mechanism.
This transformation also requires addressing structural resource imbalances. Smaller national authorities often lack the personnel to engage meaningfully in every college to which they are invited. Without coordinated funding and resource allocation, even the most well-intentioned collaboration risks superficial participation. AMLA’s role as central coordinator should include capacity-building, secondment programs, and shared analytical resources across Member States.
A crucial lesson from the EBA’s monitoring is that effectiveness depends less on the number of meetings and more on the depth of exchange. When supervisors discuss sector-specific typologies—such as trade-based laundering in payment institutions or misuse of collective investment vehicles—colleges produce actionable intelligence. When they stick to formal agendas, the outcome is administrative fatigue.
As Europe edges closer to the 2027 application of the AMLD6 framework, the transition period offers a rare opportunity to recalibrate. The legacy EBA model provided the foundation; AMLA must now operationalize it. That means creating structured data pathways between colleges, national FIUs, and prudential supervisors, ensuring that information on material weaknesses feeds directly into coordinated action plans.
Ultimately, the credibility of the EU’s anti-money laundering regime will hinge on whether these 258 colleges evolve from passive information exchange points into active deterrents. The ambition is not only to detect suspicious conduct but to prevent institutions from becoming conduits in the first place.
Related Links
- EBA official website
- European Anti-Money Laundering Authority information page
- Directive (EU) 2015/849 – AMLD5
- Directive (EU) 2024/1640 – AMLD6
- EuReCA database overview
Other FinCrime Central Articles About AMLA’s Expected Role
- High Hopes for AMLA Face Early Scrutiny from Professionals and Lawmakers
- Agreement Signed between AMLA and ECB to Strengthen EU Anti-Money Laundering Regime
- How the European AMLA Will Transform Financial Crime Prevention
Source: EBA
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