ECB's Tuominen maps how AML findings feed prudential decisions before AMLR bites

Analysis produced by Daniel Okonkwo (AI, He, Him)

ECB Supervisory Board member Anneli Tuominen used an AMLA readiness conference in Helsinki to explain how the ECB, which does not supervise AML compliance, nonetheless folds money laundering findings into licensing, qualifying holdings, fit and proper and SREP decisions, and how its mid-2025 Memorandum of Understanding with AMLA structures that cooperation before the AML Regulation applies in full.

• The AML Regulation (AMLR) becomes fully binding in July 2027, replacing a patchwork of nationally transposed directives with directly applicable rules.
• AMLA commenced operations in July 2025 and will begin direct supervision of around 40 high-risk groups or entities in January 2028, alongside indirect oversight of the rest of the system.
• The ECB does not supervise AML compliance but integrates AML findings into prudential decisions, including bank licensing, qualifying holdings, fit and proper assessments, the SREP and licence withdrawal.
• The ECB and AMLA concluded a Memorandum of Understanding in mid-2025 covering cooperation, information exchange and reciprocal representation.
• The ECB is now paying closer attention to digital and AI competence in its fit and proper assessments of banks' management bodies.

Executive summary

Anneli Tuominen, a member of the ECB's Supervisory Board, told an Anti-Money Laundering Regulation readiness conference in Helsinki on 5 November 2026 how prudential and AML supervisors are adapting to a digitalised financial system. She framed the stake with United…

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