The European Banking Authority (EBA) has released its 2025 Opinion on money laundering and terrorist financing (ML/TF) risks affecting the EU’s financial sector.
2025 marks a significant change in the ML/TF risk landscape.
In a context of important “geopolitical developments, legislative reforms and digitalisation new ML/TF vulnerabilities are emerging.”
The consistent application of the new EU legal framework “will be key to addressing these risks.”
At the same time, thanks to a “greater supervisory engagement some sectors are now better equipped to tackle financial crime.”
The EBA’s assessment has highlighted the following observations:
- FinTech: 70% of competent authorities report high or rising ML/TF risks in the financial sector. They point to weak AML/CFT controls and poor governance, as firms appear to prioritise growth over compliance.
- RegTech: over half of serious compliance failures reported to the EBA’s EuReCA database involved the improper use of RegTech tools. Despite its potential to enhance compliance, RegTech is often poorly implemented due to lack of expertise and oversight.
- Crypto Assets: this remains a high-risk sector, with a 2.5-fold increase in authorised crypto-asset service providers (CASPs) between 2022 and 2024. Many CASPs lack effective AML/CFT systems, and some attempt to bypass regulatory oversight.
- Fraud and AI: criminals are increasingly using AI to automate laundering schemes, forge documents, and evade detection. Financial institutions struggle to keep pace with these sophisticated threats, highlighting the need for responsible AI use and robust monitoring.
- Restrictive Measures: the complexity of EU sanctions regimes poses compliance challenges. Institutions often lack adequate systems to implement sanctions effectively. The EBA’s new Guidelines, applicable from end-2025, aim to harmonise standards across the EU.
Legal basis
The Opinion has been issued in accordance “with Article 6(5) of (EU) 2015/849 (The Fourth EU Anti-Money Laundering Directive), which requires the EBA to issue an Opinion on ML/TF risks affecting the EU’s financial sector every two years.”
The Opinion and its related report “inform the European Commission’s Supranational Risk Assessment (SNRA), as well as the risk assessments carried out by competent authorities and the EBA’s policies and priorities.”
