Global Investigations Review | Audrey Koh | Iman Teemul | Elinor Lee | Pillsbury Winthrop Shaw Pittman
European Union
This is an extract from the Third edition of The Guide to Anti-Money Laundering. The whole publication is available here.
This is an Insight article, written by a selected contributor as part of GIR’s co-published content. Read more on Insight
Recent years have seen an increased effort by authorities across Europe to clamp down on money laundering through a combination of legislative updates and targeted enforcement action, a trend which looks set to continue. This article examines key developments in the anti-money laundering (AML) and counterterrorist financing (CFT) landscape across Europe, with a focus on selected jurisdictions.
The evolving regulatory landscape
In 2023, the Basel Institute on Governance identified the weakest area within countries in the European Union (EU) and Western Europe to be the quality of their AML/CFT frameworks.[1] Although the 2024 assessment by the Basel Institute on Governance highlights that compliance with AML/CFT frameworks has improved across the EU and Western Europe, the effectiveness of these measures remains a major concern. The weakest areas identified were financial transparency and standards, particularly in large financial centres.[2]
There has been an ongoing effort by the European authorities to strengthen domestic and regional AML/CFT frameworks through legislative amendments and government guidance aimed at improving transparency of corporate ownership structures, effective asset recovery and increasing regulation of high-risk sectors. Geopolitical events have also shaped AML priorities across Europe – most notably, Russia’s invasion of Ukraine, and the increase in sanctions that have since followed.
Strengthening the regulatory framework: key legislative changes
European Union
The EU has significantly tightened its AML/CFT regulatory framework through a series of AML Directives over the past decade. In May 2015, the European Parliament passed the Fourth AML Directive,[3] which was implemented across the EU on 26 June 2017. The Fourth AML Directive was the most extensive update to European AML legislation in several years and was designed to strengthen the EU’s defences against money laundering and terrorist financing.
On 30 May 2024, the Council of the EU and the European Parliament adopted a sweeping package of AML/CFT reforms.[4] The package introduced the Sixth AML Directive, an EU ‘single rulebook’ regulation, and created the Anti-Money Laundering Authority (AMLA). Headquartered in Frankfurt, the AMLA will begin operations in mid-2025, with direct and indirect supervisory powers over high-risk financial entities and the authority to impose sanctions.
The Sixth AML Directive clarifies rules relating to multilayered ownership and control structures to prevent abuse of complex corporate structures, and requires foreign entities owning real estate within the EU to register details of their beneficial ownership. The package sets stricter due diligence requirements and harmonises AML rules across all private sector entities, extending the rules to crypto businesses, luxury traders and football clubs. It also streamlines national AML enforcement by strengthening Financial Intelligence Units (FIUs) and supervision mechanisms. Additionally, centralised bank account registers will be made accessible through a single access point to enhance financial crime investigations, and asset tracing and confiscation efforts.[5]
The Sixth AML Directive will take effect in tranches, and EU Member States must transpose the provisions into national legislation by 10 July 2027, except for certain real estate provisions, which are due by 10 July 2029.[6] Although the United Kingdom (UK) has not adopted the Sixth AML Directive, organisations operating within the EU must still comply with the Directive’s requirements in relevant jurisdictions and organisations will need to assess its impact on their cross-border regulatory obligations.
United Kingdom
In recent years, the UK has introduced a range of amendments and updates to its AML legislation in an attempt to combat money laundering. The UK was one of the first countries to create a public beneficial ownership register with the launch of its People with Significant Control Register in April 2016.
On 1 August 2022, the UK government established the Register of Overseas Entities through the Economic Crime (Transparency and Enforcement) Act 2022, which mandates that overseas entities holding UK property or land disclose their beneficial owners or managing officers.[7] In 2023, the UK government published its second Economic Crime Plan, outlining its plan for tackling economic crime over 2023–2026.
In addition, the Economic Crime and Corporate Transparency Act 2023 (ECCTA) was passed on 26 October 2023, introducing significant reforms to existing regulatory and corporate governance frameworks in the UK. Among other things, the ECCTA aimed to overhaul the role of Companies House (the body responsible for incorporating and maintaining companies in the UK) allowing it to challenge, reject and share information where suspicious behaviour has occurred.[8]The ECCTA will also broaden the scope of the UK’s criminal confiscation and civil recovery regimes through the Proceeds of Crime Act 2002 (POCA) to include cryptoassets. As set out in the ECCTA, from 1 September 2025, organisations can be held liable for the offence of failure to prevent fraud. This offence applies if there is a UK connection, meaning the fraud occurred in the UK or the gain or loss occurred in the UK.
The UK government also appointed a long-awaited Anti-Corruption Champion in December 2024[9] and has committed to an ‘ambitious, government-wide anti-corruption strategy in 2025’.[10] The UK government is expected to continue adapting its legal framework to combat the ever-growing threat of economic crime and ensure alignment with international standards.
Effective asset recovery as a priority
At a meeting of a joint Financial Action Task Force (FATF) and Interpol initiative in September 2023, the FATF president stressed the importance of asset recovery as a key crime prevention strategy.[11] In May 2024, the EU Directive on Asset Recovery and Confiscation came into force, with the Directive required to be incorporated into national law by 23 November 2026.[12] This Directive strengthens AML enforcement by enhancing asset tracing, freezing and confiscation across EU Member States. Member States will be required to develop a national asset recovery strategy by 24 May 2027, with updates required at least every five years. The Directive reinforces cross-border cooperation by empowering asset recovery offices to trace and identify criminal proceeds and provides asset management offices a mandate to manage frozen assets.[13]
International asset recovery remains a priority, with the EU Agency for Criminal Justice Cooperation (Eurojust) hosting a meeting in 2024 on money laundering and asset recovery to enhance cross-border cooperation among EU prosecutors, law enforcement and experts. Participants endorsed the creation of a Judicial Focus Group on Money Laundering and Asset Recovery to provide guidance on post-conviction financial investigations, confiscation orders and victim restitution.[14] Additionally, in January 2025, the European Financial and Economic Crime Centre, supported by the EU Agency for Law Enforcement Cooperation (Europol), launched Project A.S.S.E.T. (Asset Search & Seize Enforcement Taskforce), which led to the identification of millions in illicit assets and the freezing of €200,000 in cryptocurrency.[15]
Effective recovery of criminal proceeds is accordingly an important facet of the European AML/CFT strategy, with European authorities consistently pursuing asset confiscation as a stand-alone policy and operational objective.
France introduced Law No. 2010-768[16] in 2010 to improve the seizure and confiscation of criminal proceeds. In 2013, Law No. 2013-1117[17] added a presumption in the Criminal Code that property or funds without a clear justification are presumed to be crime-related. Germany, in 2017, implemented non-conviction-based asset confiscation laws, requiring prosecutors to consider confiscation in all cases.[18]
The UK’s second Economic Crime Plan (2023–2026) builds on its predecessor by further committing the government to reduce money laundering and improve criminal asset recovery during the implementation period. In this regard, the UK has established an anti-money laundering and asset recovery (AMLAR) programme, which aims to develop a new asset recovery IT system and enhance crypto-tracing technology used for asset recovery.[19] The ECCTA also broadens the scope of the UK’s criminal confiscation and civil recovery regimes to include cryptoassets, effective from 26 April 2024.
Increasing regulation in high-risk sectors and emerging threats
European authorities have recognised emerging AML/CFT risks in various sectors, namely the real estate industry, art market and cryptoassets space. The Fifth AML Directive expanded the scope of regulated entities, and the Sixth AML Directive further expands the scope to crypto businesses, luxury traders and football clubs. The crypto sector will also be subject to enhanced due diligence and information sharing measures.[20]
In Switzerland, financial intermediaries that facilitate the transfer of virtual currencies to a third party have been subject to Swiss AML/CFT regulations since 1 August 2021.[21]
Real estate
Real estate transactions are one of the most common means of laundering illicit funds in Europe. A report published in 2024 by Europol on organised crime in the region found that over one-third of the most threatening criminal networks in the EU had laundered their illegal proceeds through real estate.[22] France, in particular, is a prime hotspot for money laundering through luxury real estate purchases.
According to France’s 2024 national money laundering risk assessment, the luxury residential property market in certain regions near the country’s borders and in its overseas territories is especially vulnerable to money laundering threats, as prices are volatile and there is no set benchmark in the luxury real estate market.[23] In a report dated July 2023, Transparency International, an independent anti-corruption organisation, called on French authorities to scale up AML enforcement efforts in the real estate sector, including by pursuing entities that submit non-compliant filings or those in breach of their beneficial ownership disclosure obligations.[24]
French authorities have since launched investigations into several Russian oligarchs on suspicion of money laundering and tax fraud linked to their real estate wealth in the country. In September 2023, Paris prosecutors commenced a probe into LVMH’s chair and CEO, Bernard Arnault, and Russian businessman, Nikolai Sarkisov, on allegations of money laundering connected to luxury real estate transactions in France.[25] Two months later, in November 2023, French prosecutors charged Russian billionaire, Alexei Kuzmichev, with aggravated tax fraud and money laundering.[26] In September 2024, French authorities seized an estimated US$75 million in real estate, luxury cars and company shares as part of an ongoing investigation into two Russian individuals, Mikhail Opengeym and Ruslan Goryukhin. The investigation is ongoing.[27]
The UK remains committed to enhancing AML compliance within the real estate sector. In 2024, HM Revenue and Customs issued over £1.6 million in fines to estate agents for AML compliance failures.[28] From May 2025, letting agents are now required to report knowledge or suspicion of financial sanction breaches to the Office of Financial Sanctions Implementation,[29] aligning their compliance requirements with the regulatory obligations applicable to banks and solicitors.
Art market
The high price volatility and anonymity of transactions in the art market are key factors that make it an attractive way for criminals to launder dirty money.[30] In recent years, the crackdown on the illicit art and antiquities trade has picked up momentum in Europe, in the wake of a slew of international art trafficking cases that have ensnared prominent figures in the art world.[31]
An ongoing investigation into an art smuggling ring involves the alleged sale of looted artefacts to major museums, including the Metropolitan Museum of Art and Louvre Abu Dhabi. Arising from this investigation, former Louvre president Jean-Luc Martinez was charged in May 2022 by French prosecutors for complicity in gang fraud and money laundering. The French High Court upheld the charges on 14 November 2023, and the case remains pending.[32]
European authorities have accordingly recognised the need for heightened scrutiny of this sector. In the UK, for example, the National Crime Agency (NCA) issued an amber alert in relation to UK artwork storage facilities and specialist service providers due to the potential for sanctions evasion and money laundering.[33]
Digital assets
The 2024 Europol report on organised crime identified cryptocurrencies as an increasingly attractive means of money laundering, with one-tenth of the most threatening criminal networks in the EU using cryptocurrencies to launder illicit gains.[34] Indeed, the sheer amount of cryptocurrency that European authorities have seized in recent enforcement operations within the region reflects the size of the problem. Enforcement actions related to cryptocurrencies are already increasing across Europe, with further escalation anticipated.
In 2018, the UK police seized over £2 billion worth of bitcoin in wallets held by an individual named Jian Wen, in the largest bitcoin seizure in the UK. The bitcoin was acquired by Zhimin Qian (also known as Yadi Zhang) through a £5 billion investment scam in China. Wen was recruited to help Qian launder the scam proceeds by converting significant amounts of bitcoin into cash, real estate and jewellery. Wen was convicted by the Crown Court in March 2024[35] and was ordered to pay £3.1 million, with failure to pay potentially resulting in an additional seven-year prison sentence.[36] Qian was charged on 24 April 2024 with two counts of illegal possession of cryptocurrency[37] and civil recovery proceedings have been initiated against Qian.[38]
In July 2024, the Financial Conduct Authority (FCA) fined CB Payments Limited (CBPL), part of the Coinbase Group, £3.5 million for failing to comply with restrictions on high-risk customer onboarding. CBPL was prohibited from onboarding high-risk customers under a 2020 voluntary requirement due to concerns over its financial crime controls. However, the firm failed to implement proper compliance measures, resulting in 13,416 high-risk customers depositing US$24.9 million which facilitated US$226 million in crypto transactions. The FCA cited CBPL’s weak financial crime controls, warning that the FCA will not tolerate such lax controls. This marked the first enforcement action under the UK’s Electronic Money Regulations 2011.[39]
In September 2024, the FCA brought its first proceedings against an individual for illegally operating unregistered cryptocurrency ATMs. Olumide Osunkoya processed £2.6 million in transactions without the required FCA registration between December 2021 and September 2023. Despite being denied FCA registration, he continued operating 28 crypto ATMs, later reducing the network to 12 machines, and used a false identity to avoid being detected. On 28 February 2025, Osunkoya was sentenced to four years in prison for illegally operating unregistered crypto ATMs, forgery and money laundering offences. The FCA has initiated confiscation proceedings under POCA to recover any illegal profits.[40]
The UK is not the only country whose agencies are cracking down on illegal crypto ATMs. In August 2024, Germany’s Federal Financial Supervisory Authority (BaFin) seized 13 illegal crypto ATMs across 35 locations, and retained €250,000 in cash.[41]
In March 2023, German authorities seized €44 million in digital currency in a takedown of ChipMixer, a cryptocurrency laundering service that mixed its users’ bitcoin deposits with each other’s so as to obfuscate their origins and make it difficult for authorities to trace underlying transactions.[42] ChipMixer is estimated to have laundered around €2.8 billion during its operations.[43]
France is also stepping up its enforcement efforts against cryptocurrency-related financial crimes. French authorities have expanded their scrutiny of Binance, the world’s largest crypto exchange, over allegations of tax fraud, money laundering and illegal marketing practices. The initial probe began in 2023; however, following reports of user losses, the probe has now broadened to cover activities from 2019 to 2024.[44]
It is increasingly evident that countries throughout Europe are ramping up enforcement actions against illegal cryptocurrency operations.
Recent prosecutions and enforcement trends
The tightening of existing AML/CFT regimes within Europe continues to be complemented by robust enforcement against financial service providers, given their privileged position to detect suspicious activity.
This section examines emerging trends in recent prosecutions and regulatory fines across France, Germany, the UK and Switzerland.
France
In 2014, the National Financial Prosecutor’s Office (PNF) was established to deal with serious economic and financial crime throughout France. In recent years, the PNF has directed most of its attention towards fighting tax evasion, with most French money laundering charges pursued in that context. The harsh penalties handed down – often targeting banks and their senior management – demonstrate the rigorous approach of French enforcement authorities in this area.
In October 2017, HSBC entered into France’s first deferred prosecution agreement (CJIP), agreeing to pay €300 million to the French authorities to settle a long-running investigation in relation to allegations that its Swiss private banking unit had assisted clients in evading tax.[45]
In December 2021, Swiss Bank UBS AG was convicted by a French court on charges of unlawful solicitation and aggravated laundering of the proceeds of tax fraud, linked to its business activities in France between 2004 and 2012.[46] The court imposed a €3.75 million fine, ordered it to pay civil damages of €800 million and issued a €1 billion confiscation order. On UBS’ appeal of the decision, the French Supreme Court upheld the convictions but ordered a new trial in respect of the quantum of the fine.[47]
In October 2022, Credit Suisse agreed to pay €238 million under a CJIP to avoid prosecution in respect of allegations that Credit Suisse had created offshore entities to assist its clients to avoid declaring their assets to the French tax authorities. A PNF probe commenced in 2016 found that 5,000 French nationals held undeclared Credit Suisse bank accounts that hid over €2 billion collectively.[48]
A particular type of tax evasion that has come into the spotlight of recent enforcement activity in the region involves ‘cum-ex’ and ‘cum-cum’ trading schemes.[49] These schemes reportedly cost taxpayers globally €150 billion, including €33.4 billion in France and €36 billion in Germany.[50] In March 2023, French and German prosecutors conducted a joint raid of the Paris offices of five banks, including HSBC, Société Générale and BNP Paribas for suspected tax fraud and money laundering offences in connection with cum-cum trading,[51] linked to PNF investigations opened in December 2021.
Germany
Historically, German enforcement authorities have faced criticisms for taking a reactive rather than a proactive approach to the identification of money laundering, and for failing to prioritise money laundering as a distinct offence from the predicate crime.[52] Recent years have signalled a shift in strategy, with the German government enacting various legislative amendments to strengthen its AML/CFT regime and align its domestic framework with EU standards. Notably, in March 2021, Germany considerably expanded criminal liability for money laundering by introducing a new version of the money laundering offence. The offence adopts an ‘all crimes’ approach, where any criminal offence could be a predicate offence for money laundering.[53]
Following a critical report issued by the FATF in August 2022, which stated that Germany needed to do more to proactively and systematically investigate and prosecute money laundering activity,[54] the German government passed the Combating Financial Crimes Act, effective 1 January 2024. This legislation establishes a specialised AML agency, called the Federal Office to Combat Financial Crimes (BFF), to oversee the fight against money laundering, the prosecution of financial crimes and the investigation of suspicious transactions. Importantly, the BFF will be guided by a ‘follow the money’ principle to identify money laundering networks, addressing previous criticisms that the German enforcement approach was overly focused on pursuing predicate offences, to the neglect of large money laundering schemes.[55] It is anticipated that the BFF, which is expected to commence work in 2025, will lead to an increase in enforcement activity in Germany.
BaFin has also stepped up its efforts in AML supervision and has increased its on-site inspections for the financial sector. In 2022, BaFin conducted 48 inspections, increasing to 66 in 2023, and the authority has confirmed a further rise in 2024.[56]
Regulatory action against financial service providers for AML failings has intensified in Germany, particularly in relation to breaches of reporting obligations. In October 2020, Deutsche Bank was fined €13.5 million for failing to promptly report 627 suspicious transactions linked to the Danske Bank scandal.[57] In September 2024, Danske Bank also agreed to pay €6.33 million to settle an investigation by the French authorities into the same probe.[58] Separately, in 2022, Deutsche Bank paid an administrative penalty of €7.01 million to settle a probe in relation to 701 unfiled suspicious activity reports.[59] Additionally, in April 2024, BaFin fined Commerzbank €1.45 million for failing to meet AML obligations.[60]
Banks aside, Germany’s largest fintech company, Solaris, was fined €6.5 million by BaFin for a systemic failure to promptly report suspicious transactions.[61]
German authorities have also targeted cum-cum and cum-ex schemes. In 2021, Hamburg prosecutors charged former British hedge fund manager Sanjay Shah and six others in Germany for alleged laundering of the proceeds of cum-ex tax deals in Denmark and Belgium.[62] In October 2023, the six men charged alongside Shah each agreed to pay between €30,000 and €100,000 to settle their German money laundering charges.[63]
United Kingdom
Much like in France and Germany, the UK has seen robust enforcement of AML regulations against those who stand at the front line of the fight against money laundering, with regulators significantly stepping up their efforts.
In 2021, the FCA commenced the UK’s first criminal prosecution under the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, which set out the UK’s AML/CFT framework. The FCA charged NatWest for failing to adequately monitor or scrutinise suspicious activity by its customer Fowler Oldfield, a jewellery business. NatWest pleaded guilty to three charges of failing to comply with the relevant AML regulations and was sentenced to a fine of almost £265 million.[64] On 7 March 2025, four individuals central to the money laundering operation were sentenced to 10 to 11 years’ imprisonment for their involvement in the money laundering operation, with 12 cash carriers already convicted for their actions. The Crown Prosecution Service described this as one of the largest money laundering prosecutions brought before the courts in England and Wales, with the total laundered amount estimated at £266 million.[65]
There has similarly been a significant uptick in terms of administrative fines. In December 2021, the FCA fined HSBC £64 million for failings in its AML practices, noting that the bank had been made aware of the weaknesses in its AML monitoring processes several times before taking any action,[66] and, in December 2022, Santander UK Plc was fined £107.7 million by the FCA for failing to manage its AML systems, with the FCA finding that Santander had repeatedly failed to monitor deposits made into customers’ accounts and close suspicious accounts.[67]
In the past year, the FCA has stepped up the use of its regulatory and enforcement powers. As at December 2024, the FCA was handling 406 active investigations[68] with fines totalling over £176 million.[69]
In October 2024, the FCA fined Starling Bank Limited £28.9 million for repeatedly breaching restrictions in relation to opening accounts for high-risk customers and for financial crime failings. The FCA described Starling Bank’s financial sanction screening controls as ‘shockingly lax’. The case was resolved in just 14 months, which is significantly faster than the FCA’s average enforcement timeline of 42 months.[70]
In November 2024, the FCA fined Metro Bank £16.67 million for failures in its money laundering controls between June 2016 and December 2020. This was triggered by a data error in an automated monitoring system, which meant that transactions made on the same day as accounts were opened and subsequent transactions were left unmonitored, leading to £51 billion in untracked transactions. Staff raised concerns in 2017 and 2018, but the issue was not resolved until 2019. Additionally, Metro Bank did not have a process in place to ensure transactions were correctly monitored until December 2020.[71]
The FCA is continuing enforcement action in relation to cum-ex trading and laundering of the related proceeds. In July 2022, the FCA imposed a fine of almost £2.04 million on the UK-based investment brokerage TJM Partnership Limited (in liquidation). The FCA found that TJM lacked effective procedures, systems and controls to detect and prevent fraudulent trading and money laundering risks. These failures between January 2014 and November 2015 related to transactions executed for Solo Group.[72]
Fast forward three years, the FCA has now brought its seventh and eighth case in relation to cum-ex trading. In January 2025, Arian Financial LLP was fined almost £289,000 for failing to implement adequate financial crime controls, exposing it to the risk of fraudulent trading and money laundering linked to the Solo Group.[73] In February 2025, Mako Financial Markets Partnership LLP were fined over £1.6 million for failing to maintain adequate financial crime controls and systems and for failing to identify concerns in other Solo Group related transactions.[74]
Other UK regulators have also stepped up on enforcement, demonstrating a clear trend of increasing the fines imposed on regulated entities for AML compliance failures. The Solicitors Regulation Authority (SRA) fined 44 law firms a total of £556,832 between 2023 and 2024 for poor AML practices, with the largest fine being £101,357.[75] The SRA conducted 545 inspections and reviews during 2023–2024, nearly double the number from the previous year, and took regulatory action against a total of 78 firms.[76] The SRA has continued this trend into 2025, with a law firm being fined £31,000 in February[77] and another fined £300,000 with a £62,000 costs payment in March for AML failures.[78]
The Gambling Commission also concluded 26 enforcement cases against gambling operators over a 15-month period, with three William Hill Group businesses paying a record total of £19.2 million in March 2023 in a regulatory settlement over ‘widespread and alarming’ failures in its AML and social responsibility controls.[79] Entain was fined £17 million in August 2022 for breaches of AML and customer safety regulations,[80] and in April 2024, Bet365 was fined £582,120 for AML and social responsibility failings.[81]
In January 2025 online gambling business Greentube Alderney Limited was fined £1 million, following an investigation for similar failings. This is the second fine for the company for such failings. The Director of Enforcement, John Pierce, warned that repeat violations would lead to stricter penalties and emphasised that AML breaches will not be tolerated.[82]
Switzerland
Enforcement against banks in Switzerland has increased since 2016, after the then head of the Swiss Financial Market Supervisory Authority, Mark Branson, stated that the threat of high fines alone was not sufficient to dissuade banks from breaking the law.[83] Swiss authorities have since intensified actions against non-compliant banks – a trend that looks set to continue.
In 2021, the country saw its first criminal prosecution of a bank for corporate criminal liability in respect of money laundering, with Falcon Private Bank standing trial for money laundering charges in relation to the 1MDB scandal involving the Malaysian state fund.[84] Although the conviction was subsequently overturned on appeal due to insufficient evidence of the predicate offence,[85] this prosecution marked a shift towards a more aggressive enforcement approach by the Swiss authorities.
Just six months after the Falcon Bank trial, in June 2022, Credit Suisse was convicted by the Federal Criminal Court for failing to prevent a Bulgarian cocaine trafficking ring from laundering its illicit profits through the bank from 2004 to 2008.[86] Credit Suisse was sentenced to a fine of 2 million Swiss francs and ordered to pay 19 million Swiss francs in compensation.[87]
Concurrently, the fight against organised crime is also a strategic priority for the Office of the Attorney General of Switzerland (OAG).[88] In this regard, the OAG has directed a large part of its investigation and enforcement efforts towards prosecuting international cases of money laundering, including the 1MDB scandal.
As at April 2024, the OAG had approximately 20 open criminal proceedings in relation to the international corruption case known as Lava Jato, which has its epicentre in Brazil, including three against financial institutions.[89] In conjunction with the Lava Jato case, on 28 March 2024, the OAG found that PKB Privatbank AG failed to have in place sufficient AML measures and procedures to prevent two of its employees from laundering over US$20 million, and ordered the bank to pay 750,000 Swiss francs in a summary penalty order.[90]
In November 2024, the OAG indicted Lombard Odier Bank and a former employee for aggravated money laundering, alleging they had facilitated the concealment of criminal proceeds linked to Gulnara Karimova, daughter of the former Uzbek president. Prosecutors allege that Lombard Odier Bank failed to implement adequate AML controls, allowing persistent money laundering activities to go undetected between 2008 and 2012.[91] The OAG also concluded its investigation into Morgan Stanley (Switzerland) GmbH on 27 February 2025 relating to AML deficiencies. The OAG imposed a fine of 1 million Swiss francs for failing to prevent illicit transactions linked to bribery in Greece.[92]
International cooperation
There has been a clear movement in recent years to facilitate greater cooperation and coordination between national investigation and enforcement authorities within Europe and information sharing is becoming more prevalent. European bodies such as Europol and Eurojust play a significant role in coordinating parallel investigations between EU Member States in relation to international crime and cross-border money laundering. Outside the EU, Eurojust has concluded international cooperation agreements with 12 non-EU countries, including Iceland, Norway and Switzerland.[93] In 2023, Eurojust dealt with over 2,200 cases involving money laundering, noting that this was a 20 per cent increase from 2022.[94]
The NCA’s investigation, Operation Destabilise, is a key example of international cooperation. In December 2024, the NCA dismantled a multibillion-dollar Russian money laundering network linked to cybercrime, drugs and espionage, resulting in the seizure of £20 million and 84 arrests. Two key Russian networks laundered illicit funds using cryptocurrency and cash couriers, enabling Russian elites, cybercriminals and drug cartels to evade sanctions. Several individuals received prison sentences, and a number of high-profile figures were sanctioned by the US Office of Foreign Assets Control (OFAC). The operation was conducted through close collaboration between the UK, the EU and international law enforcement agencies, including Europol, OFAC and authorities in Ireland, France and the United Arab Emirates. Operation Destabilise demonstrates the power of coordinated efforts in disrupting transnational financial crime.[95]
Joint investigation teams
One international cooperation tool used widely by European authorities to coordinate cross-jurisdictional enforcement action is joint investigation teams (JITs), which are supported by Europol and Eurojust. A JIT is formed through a legal agreement between competent authorities of two or more EU Member States to carry out criminal investigations, and can consist of law enforcement officers, prosecutors, judges and other relevant personnel.[96]
JITs are a highly efficient and effective cooperation tool, as they allow evidence gathered in one participating Member State to be shared with others within the JIT based on the JIT agreement, without requiring the use of formal mutual legal assistance channels.[97] JITs can also be set up with non-EU countries if there is an international treaty basis to underpin the cooperation.[98]
Between 2019 and 2022, Eurojust reportedly supported 401 bilateral and 97 multilateral JITs.[99] Non-EU countries participated in 166 of the supported JITs, with the UK and Switzerland being the most frequent non-EU participants. In 2023 alone, Eurojust supported 300 JITs, a third of which were new for 2023, representing a 9 per cent increase compared to 2022.[100]
There have been several examples of European authorities taking coordinated action in respect of cross-border money laundering by or on behalf of organised crime groups. In 2016, Swiss and Italian authorities established a JIT to coordinate transnational investigations into the Italian mafia organisation, ‘Ndrangheta, one of the most powerful organised crime syndicates in the world. Pursuant to that JIT, the Swiss OAG commenced criminal proceedings against six Italian nationals, most of whom were resident in Switzerland, for their suspected participation in the organisation and associated money laundering activities.[101] In June 2022, authorities in Italy, Romania, Bulgaria and Switzerland conducted a coordinated action against a group suspected of laundering money for the ‘Ndrangheta, resulting in the arrest of the main suspect and the seizure of assets worth over €4 million.[102] In May 2023, Eurojust coordinated a large-scale joint action involving 10 countries, resulting in the arrest of 132 ‘Ndrangheta members.[103]
In February 2024, following a JIT between Germany and Latvia, national authorities in Germany, France, Italy, Latvia and Malta arrested four suspects in relation to investigations into a Maltese financial institution that had allegedly laundered at least €4.5 million for a Russian–Eurasian criminal network using various sham corporate structures since 2015.[104] In January 2025, a JIT set up between Spain, Cyprus, Germany, assisted by France, saw 23 individuals arrested for running a €100 million money laundering scheme. The network operated as a financial service for other criminal organisations, transferring illicit profits globally using cash couriers and cryptocurrency transactions.[105]
The effective and increased use of JITs reflects a growing commitment to cross-border collaboration in the fight against money laundering.
Harmonising AML/CFT frameworks across the European Union
The EU has also been active in developing a pan-European approach to AML supervision through various legislative proposals.
Following several high-profile AML failings involving European banks, the European Commission proposed enhancing the European Banking Authority’s (EBA) remit and power regarding the implementation of the EU’s AML Directives.[106] Since 1 January 2020, the EBA has been responsible for leading, coordinating and monitoring the AML/CFT efforts of all EU financial service providers and competent authorities. In this regard, the EBA has published several guidelines that seek to harmonise the AML/CFT frameworks and supervisory approach across EU countries.[107]
In its fourth review, the EBA noted significant improvements in AML supervision but highlighted that persistent challenges remain regarding risk assessment methodologies and enforcement measures. The EBA will conduct a follow-up review in 2025 before transferring its AML/CFT mandate to the AMLA on 31 December 2025.[108] Meanwhile, the EBA has launched a public consultation on four draft regulatory technical standards that will shape the EU’s new AML/CFT framework to ensure harmonised AML/CFT compliance across EU Member States.[109]
The AMLA will directly supervise entities in sectors with the highest AML risk, including cryptoasset service providers, thereby taking over from the EBA’s role as the EU’s AML/CFT supervisory body. The AMLA is expected to publish regulatory technical standards, guidelines, recommendations and opinions with the aim of harmonising supervisory practices and standards across all Member States. The AMLA will also host the central online financial intelligence system and facilitate information exchange and cooperation among FIUs.
In addition, the EU will also transfer all AML/CFT rules relating to the private sector to a new regulation, which will be directly applicable in all EU Member States, bypassing the need for national implementation. This will, for the first time, harmonise the AML/CFT rules at EU level.[110] In this context, the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) – Europe’s regional FATF-style body – is responsible for assessing the domestic AML/CFT systems of the 35 European jurisdictions under its oversight. It ensures compliance with the FATF’s standards and makes recommendations to national authorities.[111]
Conclusion
As Europe strengthens its AML/CFT frameworks, enforcement actions continue to escalate across financial institutions and high-risk sectors such as cryptocurrencies and digital assets. AML/CFT enforcement in Europe is expected to continue growing for the foreseeable future, particularly given the new AMLA, the UK’s AMLAR and Germany’s BFF, alongside the implementation of the EU-wide AML/CFT package. Given the ever-evolving landscape, it will be more crucial than ever to stay informed about the latest developments in AML/CFT legislation and guidance in the region.
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