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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In this episode of Integrity Insights, host Filip Brokes is joined by Professor Niels Appermont, a professor of economic law at Hasselt University in Belgium, and an expert in sports law. Neils discusses his research into money laundering in football, with a particular focus on Belgium’s fight against corruption and the broader challenges of enforcing anti-money laundering (AML) regulations in the sport.

Niels shares insights into the Operation Zero scandal, a 2018 Belgian investigation that exposed widespread corruption, money laundering, and match-fixing in professional football. The investigation led to reforms in Belgium's legal framework, including the introduction of AML regulations for football clubs.

Key themes discussed:

• The scope of money laundering in football: Neils explains how football has long been a target for illicit financial flows, with many clubs and agents using shell companies, false invoicing, and match-fixing to cover up corruption and illegal activities.
• The Belgian response: After Operation Zero, Belgium introduced AML regulations that cover professional football clubs, making them responsible for client identification, beneficial ownership checks, and monitoring potentially suspicious transactions.
• Key challenges: Neils discusses the practical difficulties Belgian football clubs face when implementing AML measures designed for the financial sector. These include issues with defining who qualifies as a “client” and dealing with the complexity of football transactions such as player transfers and sponsorship deals.
• International lessons: We also compare Belgium’s experience to the upcoming EU-wide AML regulation for football clubs, set to take effect in 2029. Neils explains the key differences and areas where Belgium has been a pioneer in implementing AML measures in football.

Key Takeaways:

• Money laundering in football is a significant problem, but it's hard to quantify due to the opaque nature of the sector.
• Belgium's proactive stance on AML in football makes it one of the few countries in the EU to regulate football clubs under AML obligations.
• Football clubs face unique challenges when trying to implement AML measures due to the complex nature of football transactions and the international scope of the sport.
• The upcoming EU-wide AML regulations for football clubs could lead to a fragmented approach that may not fully address the sector’s risks.

Listen now to explore the intersection of football, corruption, and financial crime and learn more about the evolving regulatory landscape in European football.

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In this episode of Integrity Insights, Filip is joined by Michael Hornsby and Elisabetta Marinoni, researchers working with Transparency International and the Anti-Corruption Data Collective (ACDC), to discuss their new study: the Opacity in Real Estate Ownership (OREO) Index.

The conversation explores how opaque real estate ownership structures enable corruption and money laundering, why data and legal frameworks both matter, and what their assessment of 24 jurisdictions reveals about global weaknesses in this sector.

Key themes discussed:

Why real estate matters for financial crime

Real estate remains a preferred vehicle for laundering illicit funds. High-value transactions and the ability to hide behind corporate structures make it attractive to corrupt actors and criminals.

What the OREO Index measures

The index evaluates 24 jurisdictions, including G20 economies and major financial hubs such as Hong Kong, Singapore, Panama and the UAE.
It assesses two pillars:

• Data – the availability, completeness and openness of property and ownership data.
• Legal framework – the strength of AML rules governing real estate transactions and professionals.

The biggest loophole: missing beneficial ownership data

Most countries do not collect beneficial ownership information when property is registered.
This means properties can be owned anonymously through companies, especially foreign companies, making it extremely hard for authorities or journalists to trace real ownership or identify patterns of suspicious acquisitions.

Cross-border gaps and obstacles for investigators

Foreign companies can often buy property without any local presence, meaning no local BO disclosure. Investigators must then rely on the rules—and cooperation—of the company’s home jurisdiction, which is often limited or opaque.

Cash purchases and absence of gatekeepers

Some countries allow property purchases in cash and do not require involvement of notaries or lawyers.
This bypasses banking-sector AML controls and removes an important oversight layer.

Uneven AML obligations for real estate professionals

While most countries extend AML requirements to real estate agents, developers and lawyers are often excluded, creating entry points for money laundering.
In some jurisdictions, lawyers can even refuse to submit suspicious transaction reports due to client-privilege provisions.

Weak supervision and fragmented oversight

Supervision is often fragmented across many bodies—Germany, for example, has over 300 supervisory authorities in the non-financial sector—making consistent enforcement difficult.

How jurisdictions compare

• South Africa ranks high on paper, but enforcement gaps remain.
• Germany scores well legally but poorly on data transparency.
• Singapore and Hong Kong perform relatively well, though Hong Kong maintains weaker BO rules.
• The UAE scores poorly, reflecting high anonymity and the “open door” model that has historically attracted illicit funds.

Future outlook: risks of backsliding

Despite years of debate, there is still no global consensus that beneficial ownership transparency in real estate is essential.

Read the full report here: https://www.transparency.org/en/publications/opacity-in-real-estate-ownership-index-2025

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