The EU is preparing more uniform sanctions for banks, companies, and professionals that violate anti-money laundering rules.
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Authorities in the European Union will have a common method for sanctioning violations of anti-money laundering and counter-terrorism financing rules. The Authority for Combating Money Laundering, AMLA, has published the final technical standards that establish how the severity of a violation should be assessed, how fines are chosen, and when harsher administrative measures can be used.
In short
AMLA introduces a common framework for the enforcement of sanctions for violations of AML/CFT rules in the EU.
Violations will be assessed based on common indicators, such as duration, repetition, impact, the conduct of the entity, and the risk of money laundering or terrorism financing.
The severity of violations will be classified into four categories, from category one to category four.
Violations in categories three and four will be considered serious, repeated, or systematic.
The standards apply to both the financial sector and the non-financial sector, following adoption by the European Commission.
The new standards are important for banks, financial institutions, firms, professionals, and other entities that fall under European anti-money laundering rules. Currently, the same violation can receive different responses depending on the member state or the supervisory authority. AMLA states that the standards aim for the same violation, under the same circumstances, to lead to the same type of law enforcement outcome across the entire European Union.
The final report shows that supervisors will follow three steps. First, they will assess the severity of the violation based on a common list of indicators. Then, they will categorize the violation into one of the four severity categories. In the third step, they will determine the level of the fine or appropriate administrative measure, using common criteria.
The indicators include the duration of the violation, the repeated nature, the conduct of the responsible person or entity, the impact on the entity, the impact on the risk of money laundering or terrorism financing, the nature of the violation, and the existence of structural deficiencies in the internal control systems. Supervisors will also analyze whether the violation could have facilitated criminal activities, whether it affected financial stability, the internal market, or the integrity of the financial system.
The four categories are ordered based on severity. Category one covers violations with absent or minor direct impact, of short duration and non-repeated. Category two concerns cases with moderate impact. Category three covers more serious situations, including repeated, systematic, or significantly impactful violations. Category four is reserved for cases with very significant impact, structural deficiencies, links to significant criminal activities, or serious effects on the market and financial system.
A violation categorized in category three or four will be considered serious, repeated, or systematic in the sense of the European anti-money laundering directive. This categorization matters because it can justify harsher sanctions and more severe administrative measures.
In determining fines, authorities will take into account cooperation with the supervisor, conduct after the identification of the violation, remedial measures, degree of responsibility, intentionality of the act, benefits obtained, losses caused to third parties, and the history of violations. Fines may be reduced if the entity cooperates quickly and effectively or takes real measures to stop the violation and prevent its recurrence.
The level of the sanction may increase if the person or entity does not cooperate, conceals the violation, misleads the supervisor, does not take remedial measures, obtains a financial or competitive benefit, or has had similar violations in the past.
The standards also include rules for individuals who are not themselves obligated entities but have leadership or supervisory roles. In these cases, authorities will analyze the actual role of the person, their responsibilities, and the level of involvement in the violation.
For administrative measures, AMLA details the criteria for the most severe interventions: restricting activity, suspending or withdrawing authorization, and changing the governance structure. These measures may be considered especially for violations of category three or four, when there are structural deficiencies, lack of cooperation, concealment of the violation, or ineffective internal controls.
The report also introduces the methodology for periodic penalties, a new tool within the European AML/CFT framework. These penalties are not presented as sanctions but as measures to compel an entity or person to comply with an already imposed administrative measure. They can be calculated daily, weekly, or monthly and are collected only for the period of non-compliance.
Before applying a periodic penalty, the authority must provide the person or entity with a statement of findings and grant them the right to be heard. The deadline for written observations can be up to four weeks. The decision to impose the penalty must indicate the legal basis, reasons, and the amount used to calculate the final sum.
The collection of periodic penalties will have a statute of limitations of five years, calculated from the day following the notification of the decision establishing the final amount due. Otherwise, the administrative procedure will be governed by the national law of the member state in which the penalty is imposed and collected.
AMLA has insisted that the new standards must be applied proportionally in both the financial and non-financial sectors. In the public consultation concluded on March 9, 2026, the authority received 91 responses, of which 88 were valid and published. Approximately 70% of respondents represented the non-financial sector.
Responses from the consultation supported the objective of a harmonized European regime but raised questions about proportional application to lawyers, notaries, auditors, SMEs, and individual practitioners. Some organizations warned that concepts used in the financial sector do not always fit the professions and small firms in the non-financial sector. AMLA states that it has modified articles and considerations to clarify the application of the standards in both sectors.
The standards will be sent to the European Commission for adoption. Following publication in the Official Journal of the European Union, the delegated regulation will be directly applicable in all member states. The text provides for application from July 10, 2027, with the exception of clubs and football agencies, for which application will begin on July 10, 2029.
AMLA is the new European authority for combating money laundering and terrorism financing. The technical standards are part of the new AML/CFT framework of the European Union and aim to reduce the differences between member states in how violations, fines, and administrative measures are treated.
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