Nikita Veremeev
13.12.2025 | 6 min read
Updated: 13.12.2025
In 2023–2024 global regulators recorded a historic high in fines for AML violations/CFT: aggregate amounts for banks and fintechs were measured in billions of dollars per year. At the same time, the EU is launching a single AMLR (EU AML Regulation, Single Rulebook) and creating the supranational AML agency AMLA, while in Asia and the CIS regulators are aligning requirements with FATF recommendations.
In such an environment any financial institution, whether a bank, payment system, crypto platform or international holding, no longer asks “do we need AML services”, but a question of survival: how to design AML for financial institutions so that it does not destroy the business model, but strengthens it.
I keep seeing the same picture: locally “closed” requirements in a single country, but fragmented processes, conflicts between jurisdictions and manual AML KYC procedures that do not withstand growth and regulatory scrutiny.
In this article I will break down how the key international AML requirements look in 2025, how AML standards in Europe, Asia and the CIS differ, and how to practically build an operational AML compliance that withstands inspections, scaling and digital business models. If you read the material to the end, you will have a framework for a strategy and a checklist by which the team can plan the implementation or rebuilding of its AML system.
International AML Standards and Regulations 2025
International AML standards and regulations in 2025 form a unified field of rules for financial organizations, fintech companies and crypto businesses, setting strict guidelines in the fight against money laundering and terrorist financing. In this context, the global framework — the FATF recommendations, the European initiatives 6AMLD, the new AMLR regulation and the establishment of the AMLA agency — becomes the starting point for understanding all subsequent compliance requirements and practices in 2025.
Global framework: FATF, 6AMLD, AMLR and AMLA
The basis of international regulation remains the FATF (Financial Action Task Force) recommendations: they define AML/CFT concepts, the risk‑based approach, requirements for KYC, beneficial owners, working with PEPs and predicate offences. For international companies this is the “default language” used by regulators in the EU, Asia and much of the CIS.
In Europe in 2025 the key roles are played by:
- 6AMLD (Sixth Anti‑Money Laundering Directive) – expands the list of predicate offences, strengthens personal liability and the coordination of investigations into money laundering and terrorist financing.
- AMLR (EU AML Regulation): a single directly applicable regulation, effectively a Single Rulebook, equalizing AML standards across all member states: uniform rules for KYC, AML transaction monitoring, identification of beneficiaries, AML reporting and sanctions.
- AMLA (European Anti‑Money Laundering Authority) – a new supranational supervisory body that takes direct control over the largest cross‑border banks, payment groups and crypto providers.
For businesses this means: less regulatory arbitrage within the EU and far stricter, but more predictable, supervision.
In Asia and the CIS the picture is more mosaic: some regulators almost literally adopt FATF standards and elements of the European Single Rulebook, while others retain a significant share of local specificity. The trend, however, is the same: strengthening AML risks and controls at the licensing level, requirements for technological infrastructure and mandatory AML automation.
A separate vector: the MiCA Regulation (Markets in Crypto‑Assets) and the related AML compliance for MiCA crypto‑assets. For crypto businesses in the EU this is a shift from a “grey zone” to a clear licensing regime and strict AML requirements for cryptocurrencies, including KYC, KYT (Know Your Transaction) and integration with blockchain analytics.
Key changes to AML requirements in the EU from 2025
In conversations with clients from the EU I always start with one thing: “your AML model in 2023 and your AML model in Europe 2025: these are already two different systems”.
Key shifts:
- 6AMLD and AMLR: focus on outcomes, not formalities
6AMLD expands the list of predicate offences (corruption, tax crimes, cybercrimes, environmental crimes, etc.) and strengthens cross‑border prosecution. For financial institutions this means the need to analyse the origin of funds and the logic of transactions more deeply, rather than limiting themselves to formal KYC.AMLR, in turn, consolidates requirements into a single set of rules: EU AML regulations cease to be a patchwork of directives, and the regulators’ risk appetite becomes more understandable, but also less flexible.
- AMLA and a new level of supervision
The creation of the EU AML agency AMLA changes the approach to control: the largest groups will be directly supervised by the agency, with unified AML stress‑tests, regular inspections and a pan‑European view on AML reporting and fines.For top players this means that the AML compliance officer function should operate at the group level, not at the level of individual countries.
- New KYC/KYT and Continuous KYC
Regulators are promoting the idea of continuous AML client verification (Continuous KYC): one‑time identification is no longer considered sufficient.In COREDO practice this is expressed in clients moving to:
- combining digital onboarding, AML digital onboarding and eKYC,
- regular reviews of the risk profile,
- implementing a KYT approach through transaction monitoring systems that track customer behaviour, not just one‑off transactions.
Attention to PEPs, complex trust structures and the quality of AML reporting (Suspicious Activity Reports: SAR) is increasing: regulators assess not only the presence of SARs but also their content and timeliness.
AML regulations and practice in Asia and the CIS
In Asia and the CIS we see a parallel movement: orientation toward FATF and local economic specifics.
In several Asian financial centres requirements for AML for financial institutions are being strengthened, including:
- mandatory implementation of a risk‑based approach when assessing clients and products;
- emphasis on continuous AML KYC for high‑risk segments;
- requirements for AML automation and data storage for subsequent analysis and inspections.
In the CIS some regulators are moving from “paper” AML to checking real processes: how AML transaction monitoring works, which AML standards are applied when screening PEPs, how AML reporting and fines are formed within the group.
The COREDO team implemented AML implementation in banks in Europe and Asia and in regional fintech platforms: in one case we helped a bank in Asia synchronize local requirements with the corporate policy of an international group. The solution developed by COREDO included unification of risk models, deployment of automated sanctions‑list screening and adjustment of AML practices for international companies, which was adopted by the head office as a standard for other regions.
Implementation of AML services in financial institutions
Practical aspects of implementing AML services in financial institutions begin with building a clear system of roles and responsibilities, where the key figure is the AML compliance officer.
The effectiveness of service implementation and the real reduction of risks for a financial institution depend on how the compliance function architecture is organized, how tasks are allocated between the lines of defense and how AML processes are integrated into the operational framework.
The role of the AML compliance officer and architecture functions
In 2025 the AML compliance officer is no longer «oversight of paper policy», but a full‑fledged architect of AML systems, risk and governance.
In my experience, a strong AML officer:
– is responsible for the methodology of the risk‑based approach and the risk matrix for clients, products and geographies;
– establishes engagement with regulators, including AMLA, central banks and financial supervisory authorities;
– manages SARs and internal investigations;
– defines requirements for AML automation and process optimization and technology selection.
COREDO’s practice shows: in international groups it is critical to formalize the separation between the first line (business units), the second line (AML compliance) and internal audit, otherwise AML in international corporations turns into a set of uncoordinated local solutions.
KYC, KYT, digital onboarding and eIDAS
In real projects clients increasingly ask one question: how to reconcile a convenient digital onboarding with reliable AML KYC procedures.
The operating model usually includes:
– remote identification using video‑KYC, biometrics and document verification through external providers;
– use of eIDAS standards (EU electronic identification) for clients from the EU;
– integration with government registries (company registers, beneficial owner registers, sometimes tax registers), i.e. AML integration with government registries.
The solutions the COREDO team implemented for European and Asian fintechs were built on AML API integration: a single gateway to KYC providers, registries, sanctions lists and PEP databases. This significantly reduces onboarding time and simplifies quality control.
Automation and technology: from AI to FHE
In 2025 the international players we work with almost always consider AML technologies and AI as a core element of strategy.
Key areas:
- implementation of transaction monitoring systems using AI and machine learning in AML;
- application of AML systems with machine learning and graph neural networks (GNN) to detect complex transaction networks and non‑trivial money‑laundering schemes;
- use of AML monitoring for unusual patterns to find anomalies in customer behavior, not only by static rules;
- pilots using homomorphic encryption (FHE) and advanced methods of AML data governance and privacy, allowing analysis of data in encrypted form and reducing leakage risks.
In one of COREDO’s projects for a payments group in the EU a hybrid approach was implemented: ML models are responsible for alert prioritization, while classic rules remain a «safety net» to meet the formal requirements of the regulator and internal audit. This reduced the share of false positives by more than 40% while maintaining the detection rate of suspicious transactions.
Best practices in AML monitoring and reporting
In real life the best AML practices for transaction monitoring in Europe and Asia boil down to three principles.
- Continuous monitoring and Continuous KYC
The system must track not only one‑off events but also changes in the client’s profile: sources of funds, geography of operations, changes in behavioral patterns; this is the foundation of AML continuous KYC.
- High-quality reporting and sanctions handling
- AML reporting (SAR) should be generated by clear triggers, have a clear structure and be accompanied by internal investigation documentation.
- AML filters for sanctions lists and PEP lists should be updated daily, taking into account local and international lists.
- Using AML white/black lists (Allow/Deny Lists) helps reduce repeated alerts for verified customers and, conversely, block known offenders.
- Risk‑based approach and risk management
AML risks and assessment should be quantitatively measurable: each client, product and region has its own scoring profile, which affects the depth of checks, monitoring frequency and trigger thresholds.
Our experience at COREDO has shown that when an institution formalizes such a matrix and links it to an automated system, the overall picture of AML risk and governance becomes transparent to top management and the board of directors.
AML compliance specifics for cryptocurrencies
Crypto business today: one of the sectors most sensitive to regulators.
Key elements of AML requirements for the crypto business in 2025:
- strict AML KYC procedures for all clients, including retail;
- use of KYT tools for blockchain transaction analysis;
- AML policies under the MiCA Regulation (Markets in Crypto‑Assets), including oversight of wallet providers and stablecoins;
- focus on AML in fintech and crypto business as a high‑risk area for terrorism financing and sanctions evasion.
COREDO’s practice confirms: without AML integration with blockchain analytics and thoughtful AML API integration with third‑party providers, conducting licensing checks and subsequent supervision is practically impossible. We support clients with MiCA requirements and help build AML digital identification and KYT as a unified process, not as a set of disparate tools.
Scaling and Optimization of AML in Finance
When a financial institution grows — expands into new countries, adds products, brings on partners — scaling AML systems becomes a distinct strategic challenge.
Typical risks clients bring to COREDO:
- duplication of processes and data across different jurisdictions;
- incompatible transaction monitoring systems in subsidiaries;
- lack of a unified approach to AML, sanctions and fines, and internal investigations.
The solution our team most often implements is building a single target AML architecture: a common platform, unified data and risk models, with local rules layered on top to accommodate national requirements.
AI automation and reducing false positives
The technology component delivers a noticeable impact here:
- AML automation relieves the first line (front office, operations);
- AML technologies and AI increase detection accuracy and adapt to new schemes;
- how AML systems adapt to new laundering schemes with AI — through self‑learning models, analysis of atypical transaction routes and GNN.
Modern methods for reducing false positives include: dynamic thresholds, behavioral segmentation, AML white/black lists and subsequent model calibration based on analyst feedback. The COREDO team has repeatedly built such feedback loops for banks and payment systems, helping to drastically reduce the burden on analysts without loss of quality.
Assessing AML effectiveness and ROI
Naturally, leaders are interested: how to assess the effectiveness of AML programs and ROI for the business.
Metrics we use in COREDO projects:
- share of cases processed automatically;
- ratio of false-positive alerts to confirmed incidents;
- response time to suspicious transactions;
- reduction in regulatory findings and absence of material fines;
- impact on customer experience (onboarding speed, number of rejections without objective grounds).
A properly configured AML ROI (return on investment) shows that investments in automation and methodology pay off through reduced operational costs, minimized fines and protection from reputational risks.
The role of the AML compliance officer in international organizations
In international groups, the role of the AML officer rises to the level of a strategic partner to the CEO and the board of directors.
Key tasks:
- synchronize local teams with the requirements of HQ and international regulators (including the EU AML agency AMLA);
- establish a unified approach to AML and risk management in financial institutions;
- prepare the business for inspections and stress scenarios related to AML, sanctions and fines.
The COREDO team often helps AML officers build internal communications: procedures for interaction with IT, the product team, the legal department and internal audit. Such a framework makes AML part of corporate governance and overall compliance, rather than an ‘appendix’ of the lawyers.
Key findings and recommendations for entrepreneurs
Summing up international AML practice under the international regulatory framework as of 2025, a clear set of steps emerges for financial institutions.
- Formulate a target AML compliance model
- Determine which international AML requirements apply to you (FATF, 6AMLD, AMLR, MiCA, local laws).
- Approve a unified risk appetite and an AML risk and governance matrix.
- Rebuild KYC/KYT and Continuous KYC processes
- Implement AML digital identification, digital onboarding and eKYC using eIDAS and registry integrations.
- Update AML KYC procedures taking into account new EU and Asian requirements, including working with PEPs and complex structures.
- Invest in technology and data architecture
- Choose a platform for transaction monitoring systems that supports AML solutions with machine learning, GNNs and flexible rule configuration.
- Ensure AML data governance and privacy, and consider potential use of FHE and other protective technologies.
- Ensure mature reporting and engagement with regulators
- Set up processes for SARs, sanctions screening and internal investigations.
- Prepare a dialogue strategy with AMLA and national regulators, especially if you are a cross-border group.
- Choose a reliable AML services partner
In my experience, successful projects are launched when entrepreneurs and top managers view AML not as a ‘mandatory formality’ but as an element of a long-term strategy for business security and resilience. The COREDO team, through years of work in Europe, Asia and the CIS, has helped many clients move from fragmented processes to mature, automated systems that meet the requirements of 2025 and are ready for the next waves of regulation.
If you feel that your current AML framework does not meet the challenges posed by the new regulatory cycle, this is a good time to conduct a diagnosis and build an updated strategy – drawing on international standards and the practical experience of those who have already gone this way.