Navigating the EU’s new AML regime: Practical implications of AMLR and AMLA for senior compliance and risk leaders
Abstract
The adoption of the EU Anti-Money Laundering Regulation (AMLR)1 and the establishment of the Anti-Money Laundering Authority (AMLA)2 mark a structural reconfiguration of the European Union’s anti-money laundering/combatting the financing of terrorism (AML/CFT) framework. Together, they shift the EU from nationally mediated implementation towards a directly applicable single rulebook combined with supervisory convergence anchored in demonstrable effectiveness rather than procedural compliance. This paper examines the new regime through a practitioner-informed analytical lens, focusing on how AMLR and AMLA are likely to reshape supervisory behaviour, institutional accountability, and the practical application of the risk-based approach. It argues that the reforms represent not merely legal harmonisation, but a recalibration of the relationship between regulation, supervision, and institutional decision making, in which supervisory credibility increasingly depends on the quality of risk judgment and escalation logic. Drawing on comparative insights from the Single Supervisory Mechanism, the article situates AMLA as a de facto ‘fourth line of defence’, driving convergence through common methodologies, peer-based assessment, and data-driven supervision. Particular attention is given to Article 75 AMLR and the expansion of public–private partnerships, as well as the need to reconcile enhanced information sharing with General Data Protection Regulation (GDPR) constraints. The analysis highlights reduced tolerance for national gold-plating, heightened scrutiny of proportionality, and increased visibility of inconsistencies across jurisdictions and business lines. Finally, the EU reforms are placed in a global context, assessing alignment with Financial Action Task Force (FATF) standards and the implications for the EU’s competitiveness as a financial centre. This article is also included in The Business & Management Collection which can be accessed at http://hstalks.com.business/.
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Author's Biography
Adrianna Fabijanska is a London-based purpose-driven global senior financial crime compliance, geopolitical strategist and technology risk leader, and a former regulator, with nearly two decades of experience protecting the integrity and resilience of global financial markets. Adrianna previously served as Global Head FCC - Investment Banking at ING, where she led strategic financial crime transformation. She operates at the intersection of regulation, geopolitics, and digital transformation, enabling sustainable innovation in both traditional finance and emerging technologies. She brings strategic foresight, regulatory fluency, and strong cross-functional execution across investment, wholesale, corporate, private, and retail banking, with senior leadership experience spanning the UK, Europe, the Middle East and Africa (ENA), Asia-Pacific, and the Americas. Adrianna is trusted by boards, CEOs and supervisory authorities to lead complex regulatory remediation, deliver enterprise-wide enhancement programmes, and translate geopolitical, cyber-enabled and emerging technology threats into decisive risk strategy with measurable impact. A recognised authority on digital asset compliance, blockchain and distributed ledger technology (DLT) governance, and stablecoin risk management, she focuses on embedding AI-driven intelligence into financial crime frameworks to demonstrate operational effectiveness and strengthen institutional trust. Her work increasingly addresses next-generation risks, including cyber resilience, data integrity, and quantum accelerated threats. Adrianna is an influential industry voice on the future of secure finance, actively contributing to regulatory dialogue and public–private collaboration on emerging financial crime risks. Her professional mission is to build trusted financial infrastructure that aligns innovation with integrity, supporting long-term value creation, market confidence, and financial system stability.
