AML CFT Roundup 2025: What changed, and what comes next

In this episode of Integrity Insights, Filip is joined by Jennifer Hanley-Giersch to review the biggest AML/CFT developments of 2025. They discuss why the year marked a shift from incremental updates to structural change, driven by AMLA’s launch, preparation for the EU Single Rulebook, tougher sanctions expectations, and a renewed focus on terrorist financing.

Key themes discussed

• AMLA and the EU Single Rulebook
  Although the regulation applies from July 2027, firms face earlier deadlines. From October 2026, national supervisors will collect new risk and controls data to feed AMLA’s risk-scoring model, forcing many institutions to remediate data gaps.
• FinTech and RegTech under pressure
  Supervisors reported rising risk from FinTechs, often linked to weak governance and immature controls. Jennifer highlights that many serious failures involve poorly implemented RegTech tools and lack of expertise.
• Germany: BaFin guidance and FIU progress
  BaFin’s updated guidance increased expectations around risk assessments (including separating money laundering and terrorist financing risk), residual risk, outsourcing oversight, AML officer responsibilities, and customer data update cycles. The German FIU also reported fewer but higher-quality STRs, with more referrals to law enforcement.
• Terrorist financing and crypto enforcement
  Crypto remains a major risk area, but 2025 showed stronger enforcement momentum, including disruption of terrorist fundraising and takedowns of anonymisation infrastructure such as mixers.
• Sanctions and circumvention
  The episode highlights evolving circumvention models linked to Iran and Russia, and the continued willingness of EU and US authorities to impose substantial penalties where firms knowingly facilitate sanctioned interests.
• Cyber fraud and operational resilience
  They close with the growing impact of cybercrime and DORA-driven supervision of critical ICT providers, reinforcing that resilience is now a core component of financial integrity.

Key takeaway: 2025 accelerated the move toward centralised supervision, higher data expectations, and closer links between AML, sanctions, crypto, and cyber resilience.

Related content:

AMLA's work program: https://www.acams.org/en/opinion/amlas-work-program-and-its-enhanced-oversight-of-casps

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