2025 was an important year in anti-money laundering and financial crime regulation, and 2026 is set to bring even more challenges and complexity for financial institutions. This, according to Fenergo’s insights which were obtained from professionals that had discussed various upcoming regulatory trends and had also evaluated their potential impact on compliance programs around the world. The update from Regtech Fenergo provides region-by-region exploration of regulatory evolution – offering “a clear picture of what must be prioritized for 2026.”
As noted by Dublin based Regtech firm Fenergo, the U.S. is entering a period of structural reform, driven largely by the ongoing implementation of the AML Act 2020 and the Corporate Transparency Act.
PwC’s MD of Risk and Regulatory Affairs, Greg Calpakis highlighted the Investment Adviser AML Rule and beneficial ownership registry requirements in the regulatory pipeline.
Greg explained that political transitions have slowed progress.
He said, “that’s why requirements and deadlines from the AML Act are now past their due date but the federal agencies continue to look forward to passing those hopefully in the coming year or so.”
Rory Doyle, Principal Regulatory Specialist, Fenergo explained that deregulation is really a resource-optimization effort:
“This is essentially about applying what the Europeans have done for the last 20 years, which is taking a risk-based approach.”
Sanctions continue to be an area of compliance that changes quickly.
The panel discussed the new operational challenges 2026 are likely to deliver in this area.
Rory described traditional synergies in sanction regimes between Western financial systems beginning to diverge:
“An entity may now get sanctioned in the EU but not be sanctioned in the US”. For multinational institutions, this calls for far more intricacy and detailed examination of financial transactions.”
He also highlighted the challenge of unwinding sanctions as geopolitical situations evolve:
“Sanctioned teams are going to have to start thinking about how to unblock accounts as sanctions are lifted.”
Adam McLaughlin, Director of Financial Crime, Fenergo added that sanctions are now being used aggressively against organized crime, referencing increase in “transnational organized crime networks being sanctioned directly by the US and even in Europe.”
AI is reshaping compliance, yet regulatory stances “vary widely,” said Sharon Bodkin, VP of Product at Fenergo.
She explained that adoption depends on “the prevalence of regulation in a jurisdiction or country”, noting that the EU’s AI Act provides boundaries.
Sharon also explained that the uneven pace of global adoption stems from the level of risk FIs are willing to take and their “operational readiness for AI.”
Sharon explained:
“In the US, it’s seen very much as a competitive advantage at a strategic level”.
Importantly, she emphasized that institutions must ensure “auditability, traceability and governance” to satisfy regulators globally.
Fenergo’s AI powered FinCrime Operating System can add real value to financial institutions looking to achieve this.
EU harmonization will progress in 2026 with a “focus on aligning the varying regulatory requirements of the 27 jurisdictions within the EU.”
But, the biggest shifts are set to arrive in 2027.
Adam described 2026 as “the planning year which will make way for 2027”.
He noted that 2026 is the year when the first supervisory priorities of the new Anti-Money Laundering Authority (AMLA) will come out.
Rory highlighted the operational impact of the AMLA’s harmonization project on FIs:
“From 2027 the stopwatch starts ticking and financial institutions have five years to implement the harmonization requirements.”
Rory noted that enhanced obligations will expand due diligence workloads:
“There will be a lot of work ahead in the run up to 2032, especially around beneficial owner.”
The APAC region is accelerating updates faster than expected.
Sharon explained that Australia’s Tranche Two reforms are moving steadily, meaning firms must “assess the current state of the policy procedures and technology” to adapt in time.
She has emphasized the importance of “testing and post implementation” reviews to ensure processes, systems and technologies “are in line with the new regulations.”
Rory noted his surprise at “the speed of which Australia brought in these reforms” and the pace at which institutions are now said to be responding.
Adam also recently drew attention to MENA’s regulatory maturity, including the UAE’s “fundamental reset of the law”, expanded money-laundering offenses, “ultimate beneficial ownership and transparency expectations.”