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Summary
AML Event 2026
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Regulators, supervisors, bankers and AML, privacy and compliance professionals gathered for the Leaders in Finance AML Event, built around one central question: how can financial institutions balance effective AML compliance with cost efficiency in a changing technological, regulatory and societal landscape? The morning opened with a provocative keynote on why the world is failing to stop money laundering. It then covered the balance between AML and data protection, two banking panels on AI, emerging threats and the effectiveness of regulation, and a fireside chat on information-sharing partnerships in practice. DNB gave a regulator’s update, and an anonymous speaker described buying a house with cash in South America. The programme closed with a keynote from AMLA’s Executive Board on the road to the new European AML framework.
This document summarizes the speeches, interviews, panels and cases at the event. It is not a verbatim transcript, but a paraphrased synopsis of the key points made. It has been prepared and published by Leaders in Finance. Please note that this summary was created with the help of AI tools. While care has been taken to ensure accuracy, the content may contain errors or omissions. For full clarity or specific details, please feel free to contact us.
Key takeaways
- More compliance does not automatically mean better compliance. Speakers kept asking whether adding controls, alerts, staff and rules actually reduces financial crime. DNB’s Willem Schudel challenged institutions to work out which AML activities create real value and which only add cost or burden customers. AMLA’s Rikke-Louise Ørum Petersen made a similar point: success should be measured by action against financial crime, not by the number of rules, reports or inspections.
- Risk-based must also mean doing less where risk is low. Oliver Bullough’s examples of mistaken identity and repeated checks on a charity showed how defensive compliance leads to wasted work and financial exclusion. Several speakers called for lighter measures where risk is demonstrably lower, backed by evidence. Esmé Bosma (Dutch DPA) urged institutions to stop measures that offer little benefit or cause disproportionate harm, and AMLA invited proposals for simplified due diligence.
- Information sharing is the next frontier, but privacy has to be built in from the start. Commerzbank’s Nina Ihl showed how partnerships such as safeAML and COCO uncover criminal activity that no single bank can see alone. A COCO pilot suggested tens of millions in customer losses could have been prevented. The joint Article 75 guidance from AMLA and the EDPB opens the door, but speakers stressed that a legal basis is still required. They also advised starting with a small use case and involving privacy, legal and IT security colleagues from day one.
- Banks cannot fight money laundering alone. Bullough argued that banks’ heavy investment in reporting is not matched by government capacity to investigate and enforce: “This isn’t just something you can leave to the banks.” AMLA disputed that reports go unprocessed, but agreed that authorities need to give institutions better feedback and turn the information they receive into action.
- AI is a powerful tool, but it does not replace human judgement or accountability. AI-enabled identity and document fraud is a growing threat, and AI can help analysts focus on the risks that matter. Speakers warned against automating flawed processes or relying on poor-quality data. Analysts need both AML expertise and technical understanding to challenge AI output, and accountability stays with the bank even when critical technology comes from third parties.
- The European AML framework is taking shape, and the sector wants clarity quickly. With a single rulebook coming and AMLA’s direct supervision of selected groups starting in 2028, speakers welcomed convergence across Europe. They warned against simply stacking national requirements on top of European ones. Banks called on AMLA for timely guidance on AMLR implementation priorities, particularly on information-sharing partnerships.
Welcome – Leanne Joseph (moderator)
Keynote: Why We’re Failing to Stop Money Laundering – Oliver Bullough
Oliver Bullough argued that banks’ growing investment in AML compliance is insufficiently matched by government capacity to investigate and act on their reports. He illustrated the consequences of defensive compliance through cases of mistaken identity and repeated checks on a charity serving British Somali communities, highlighting unnecessary work and financial exclusion.
He also questioned the growth of large-denomination banknotes despite declining cash use for everyday payments. In the Q&A, he explained how cash and crypto can complement each other: locally collected cash can be exchanged for crypto to move value internationally. His closing appeal was for greater political urgency and investment in enforcement: “This isn’t just something you can leave to the banks.”
Balancing AML & Data Protection – Esmé Bosma
Esmé Bosma, Financial Sector Coordinator at the Dutch Data Protection Authority, asked participants whether they would share their banking transactions with a neighbour. Nobody volunteered. Her message: AML and data protection go hand in hand. Reliable data and proportionate controls support effective compliance while protecting customers against discrimination and financial exclusion.
Discussing Article 75, she highlighted opportunities for information-sharing partnerships and joint guidance from AMLA and the European Data Protection Board. Privacy-enhancing technology can support collaboration, but a legal basis remains necessary. She called for closer cooperation between AML and privacy professionals, and regular evaluation of whether controls actually work—including a willingness to stop measures that offer little benefit or cause disproportionate harm.
AML Banking Panel I – Jaap van der Molen & Vinod Jaising, moderated by Marit Hoegen
Moderated by Marit Hoegen (Deloitte), Jaap van der Molen (ABN AMRO) and Vinod Jaising (Rabobank) discussed emerging threats and AI’s role in financial crime prevention. Responding to Bullough, Van der Molen suggested rising cash volumes could reflect banks making laundering harder. He highlighted AI-enabled identity and document fraud, advocating access to verified data directly from trusted sources.
Jaising stressed that banks need better insights from existing data and stronger information sharing. Both saw AI helping analysts focus on meaningful risks, but scaling requires sound controls and continued accountability. Jaising warned against automating flawed processes or relying on poor-quality data. Analysts must combine AML expertise with technological understanding and critical thinking to challenge AI-generated findings and identify errors or bias.
Fireside Chat: Information Sharing Partnerships in Practice – Roderick Rodenburg & Nina Ihl
Roderick Rodenburg (Roseman Labs) and Nina Ihl (Commerzbank) explored how information sharing reveals criminal activity individual banks cannot see alone. Ihl described two initiatives: safeAML traces funds across multiple banks, while COCO enables rapid exchange of fraud warnings. A COCO pilot using historical data suggested potential customer losses in the tens of millions could have been prevented.
The value, Ihl explained, comes from combining different banks’ intelligence and detection methods. She advised starting with a small, practical use case, defining banks’ requirements before building the technology, and involving privacy, legal and IT security colleagues from the outset. Supervisors should remain informed. Her longer-term ambition was European cooperation supported by harmonised rules and data standards, making information sharing routine.
The Regulator’s Update in an Over-Increasing European AML Playing Field – Willem Schudel
DNB’s Willem Schudel questioned whether more controls, alerts and staff necessarily deliver greater impact. A risk-based approach requires up-to-date analysis of how an institution can be exploited, with evidence supporting both stricter controls and lighter measures where risks are demonstrably lower. Decisions must be understandable and verifiable by colleagues and supervisors.
He welcomed European supervisory convergence but cautioned against simply accumulating national requirements. In the Q&A, he acknowledged that harmonisation may initially require common rules, while risk-based supervision remains the goal. He also stressed that supervisors examine how decisions are made and how institutions learn from mistakes. His closing challenge: identify which AML activities create societal value and which impose costs or customer burdens without reducing risk.
AML Banking Panel II – Gwendolyn van Tunen & Yücel Ölçer, moderated by Vincent Gaudel
Vincent Gaudel (LexisNexis Risk Solutions) moderated a debate with Gwendolyn van Tunen (ASN Bank) and Yücel Ölçer (ING). Both questioned whether more regulation necessarily improves effectiveness. Van Tunen challenged the value of expanding PEP requirements for a domestically focused bank, while Ölçer advocated concentrating effort on genuinely high-risk customers.
On connecting fraud and AML, Ölçer explained that ING had merged the functions organisationally, but operational integration remained incomplete. ASN was working towards a merger. Both stressed that AI requires human oversight and sound governance, and supported stronger standards for critical technology providers without transferring banks’ accountability. Looking towards AMLR implementation, they called for timely clarity from AMLA, particularly on information-sharing partnerships and implementation priorities.
Intermezzo: How to Buy a House with Cash in South America – Anonymous Speaker
An anonymous speaker described buying a house in Argentina with physical US dollars, illustrating the security risks of cash-intensive property transactions and their potential use for integrating criminal proceeds.
He also explained why people hold cash legitimately: stable foreign currency can offer protection against economic instability and government intervention. Where cash is widely used for legitimate purposes, it becomes less useful as an indicator of illicit funds. He closed by emphasising the responsibility financial institutions carry when their decisions affect people’s access to their money.
Closing Keynote on AMLR – Rikke-Louise Ørum Petersen
Rikke-Louise Ørum Petersen, Executive Board Member at AMLA, outlined four priorities: a single rulebook, consistent supervision, stronger financial intelligence and cooperation, and a connected AML community. Direct supervision of selected financial groups would begin in 2028. Responding to Bullough, she disputed the suggestion that suspicious transaction reports are not processed, emphasising the need to turn information into insights and action.
She highlighted joint Article 75 guidance with the European Data Protection Board and called for better feedback from authorities to institutions. In the Q&A, she agreed that risk-based work also means doing less where risks are lower, inviting proposals for simplified due diligence within the legislation. Success, she concluded, should be measured by action against financial crime rather than volumes of rules, reports or inspections.
Wrap-Up & Closing – Leanne Joseph
Leanne Joseph closed with an audience poll showing greater confidence among many participants, alongside continuing questions. She thanked the speakers, partners and attendees and announced the next AML Event for 30 September 2027. The morning ended with a networking lunch.
Lunch & Networking
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