EU's AMLA Flags Rising Sanctions Circumvention Risk Across Member States in 2025 Report
The EU's Anti-Money Laundering Authority (AMLA) has released its 2025 Roadshow Report, drawing on consultations with supervisors, financial intelligence units (FIUs), and private sector representatives across all 27 EU member states.
On the topic of sanctions, the report identifies several key trends and concerns:
Sanctions circumvention on the rise. Since Russia's invasion of Ukraine in 2022, evading sanctions has become a significantly more prominent supervisory and enforcement challenge across the EU.
Geographic concentration of risk. The threat is felt most acutely in Baltic, Nordic, and Eastern European member states, which are geographically and economically closer to the conflict zone.
Increasingly sophisticated evasion methods. Circumvention techniques are growing in complexity, and sanctions risks are now increasingly intertwined with cyber-enabled criminal activity.
Compliance gap between sectors. Large financial institutions have invested substantially in sanctions compliance infrastructure. However, parts of the non-financial sector — including smaller businesses — have more limited resources and, in some cases, lower awareness of their legal obligations.
AMLA's next steps. The authority intends to consolidate typologies and risk indicators at EU level and enhance cross-border coordination among national supervisors.
On the topic of sanctions, the report identifies several key trends and concerns:
Sanctions circumvention on the rise. Since Russia's invasion of Ukraine in 2022, evading sanctions has become a significantly more prominent supervisory and enforcement challenge across the EU.
Geographic concentration of risk. The threat is felt most acutely in Baltic, Nordic, and Eastern European member states, which are geographically and economically closer to the conflict zone.
Increasingly sophisticated evasion methods. Circumvention techniques are growing in complexity, and sanctions risks are now increasingly intertwined with cyber-enabled criminal activity.
Compliance gap between sectors. Large financial institutions have invested substantially in sanctions compliance infrastructure. However, parts of the non-financial sector — including smaller businesses — have more limited resources and, in some cases, lower awareness of their legal obligations.
AMLA's next steps. The authority intends to consolidate typologies and risk indicators at EU level and enhance cross-border coordination among national supervisors.
- AMLA was established in 2024 with a mandate to coordinate anti-money laundering and counter-terrorist financing efforts across the European Union.
