Anti-money laundering: banks are ahead of the game on AML rules, but 58 per cent of financial intermediaries have yet to take action
Aicom-EY survey of the financial sector ahead of the introduction of new European regulations
The new European AML Package marks a turning point for the European anti-money laundering framework. But how prepared are banks and financial intermediaries for the new European rules that will come into force in 2027? A study conducted by Aicom and EY, which surveyed 52 of Italy’s leading operators, provides a snapshot of the current situation. And it must be said that the picture is still rather patchy.
By the third quarter of 2026, 19 per cent of respondents had already made plans for how to tackle the AML Package, and 23 per cent had begun to assess its implications. However, as many as 58 per cent of the sample, by contrast, had yet to take any action. This suggests, in short, that levels of preparedness vary greatly from one sector to another. In this respect, banks appear to be ahead of the curve, as nearly nine out of ten banks had either planned or begun an assessment of the issue. By contrast, amongst non-bank intermediaries, more than one in three had not yet begun to consider the matter at all. What is certain is that, for 79 per cent of respondents, the new rules will primarily affect customer due diligence.
However, the gap becomes particularly apparent when one looks at the different segments. Almost nine out of ten banks and banking groups stand out for having already mapped out a plan or, at the very least, for having begun to assess the situation. By contrast, amongst non-bank financial intermediaries, more than one in three has not yet begun to adapt. It should be borne in mind, however, that the European rules will apply from 10 July 2027, so there is still time to comply.
The research also examines the role of the AML Officer – that is, the member of the board of directors responsible for bringing anti-money laundering issues to the board’s attention, liaising with the AML function. This is an increasingly important role; according to the research, 49 per cent of respondents stated that it was held by a member of the board itself, whilst in 37 per cent of cases it was held by the chief executive.
In this regard, it must be said that there is still work to be done: to date, around 80 per cent of intermediaries that have already appointed the Designated Representative have not formalised how to handle any disagreements with the AML function. Meanwhile, in 60 per cent of cases, no direct audits of the function are envisaged, in line with its role as a governance and liaison body, rather than a supervisory one.
