1 September to 30 September
Introduction
Financial services regulators treat anti-money laundering (AML) compliance as a priority. They are strengthening their supervisory frameworks, imposing significant penalties for systems and controls failures, and dealing with emerging risks linked to crypto-assets, beneficial ownership transparency and increasingly sophisticated cross-border financial flows.
Regulation is not uniform, because jurisdictions are at different stages of reforming their AML frameworks. This is particularly true of customer due diligence, beneficial ownership and reporting obligations, and of the arrival of new supervisory bodies such as the EU’s Anti-Money Laundering Authority. Illicit finance rarely respects national borders, so a weakness in one jurisdiction can expose an institution to regulatory, criminal and reputational consequences in several others. For institutions operating across borders, this makes it a challenge to put in place consistent group-wide controls while meeting different local requirements. It is therefore critical to monitor the latest regulatory updates.
To help you, we have tracked AML regulatory developments from 1 September 2026 – 30 September 2026, from the EU, the UK, the UAE, the US and Australia as well as key international bodies, such as the Financial Action Task Force.
This month’s highlight
One market, many rulebooks – building AML frameworks that work across borders
For groups operating across several jurisdictions, 2026 has shown how quickly the AML landscape is shifting, and why a purely local approach to compliance is no longer enough.
The EU: from national supervision to a single rulebook
Under the EU AML package, the core AML/CTF obligations for regulated entities will be governed directly by the AML Regulation, which applies uniformly across Member States. The creation of the Anti-Money Laundering Authority (AMLA) marks a significant shift from a system in which AML/CFT supervision is carried out exclusively by national competent authorities. From 2028, AMLA will directly supervise financial sector obliged entities that operate in at least six Member States and have a high money laundering and terrorist financing risk profile. Each selected entity will be assigned a Joint Supervisory Team made up of AMLA staff and national supervisors, led by an AMLA coordinator.
The selection process is already under way. AMLA has issued a reporting package to identify provisionally eligible entities, with Member State supervisors collecting data by 15 August 2026. On 21 July 2026, AMLA published its final report on draft ITS setting out how it will cooperate with national supervisors, including when entities move between national and EU-level oversight.
AMLA’s policy work is equally relevant to cross-border groups. In April 2026, it consulted on draft RTS setting minimum standards for group-wide AML frameworks, including in cross-border situations and where obliged entities operate in third countries. Further consultations have covered customer due diligence and a common supervisory approach to enforcement, ongoing monitoring of business relationships and harmonised templates for reporting suspicions and providing transaction records to financial intelligence units, with comments due by 20 September 2026.
The UK: a separate but evolving regime
Post Brexit, the UK continues to refine its own rules. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June 2026, refining customer due diligence and enhanced due diligence requirements and strengthening information-sharing between AML/CTF supervisors and other public bodies. The FCA is also sharpening its supervisory focus: it published findings and good and poor practice examples following engagement with 242 asset management and alternative firms on financial crime controls, and announced increased scrutiny of Annex 1 firms such as unregulated lenders, safe custody providers and money brokers.
The US: recalibrating and extending the regime
The US is reshaping its framework rather than simply expanding it. In April 2026, FinCEN proposed a rule to fundamentally reform financial institutions’ AML/CFT programmes, promoting risk-based, reasonably designed programmes and greater consistency in how banks are evaluated. FinCEN has also postponed its AML/CFT rule for registered investment advisers and exempt reporting advisers from 1 January 2026 to 1 January 2028, and intends to revisit its scope. Stablecoins are being brought firmly within the perimeter: FinCEN and OFAC proposed in April 2026 that permitted payment stablecoin issuers under the GENIUS Act be treated as financial institutions and maintain AML/CFT and sanctions compliance programmes, followed in June 2026 by a proposed customer identification programme rule.
The UAE: enforcement after the grey list
Since its removal from the FATF grey list in February 2024, the UAE has markedly increased enforcement, with the Central Bank (CBUAE) issuing over AED 370 million in AML/CFT fines in 2025 alone. In June 2026, the CBUAE fined the UAE branch of a foreign bank AED 20 million for repeated AML/CFT and sanctions failures, and personally fined its Head of Compliance and MLRO AED 300,000. The action coincided with the UAE’s FATF fifth round mutual evaluation, and is a warning that foreign bank branches relying on home-country compliance programmes may fall short of UAE expectations. Federal Decree Law No. 10 of 2025 introduced personal liability for managers and a lower evidentiary threshold for proving knowledge of criminal proceeds. In January 2026, Dubai’s VARA required virtual asset service providers to apply enhanced due diligence to relationships linked to high-risk jurisdictions and prohibited reliance on due diligence providers in FATF black-listed jurisdictions.
Crypto-assets show most clearly how the four regimes are converging on the same risks by different routes. AMLA has issued an advisory note on money laundering risks as the MiCA transitional period ends, while the FCA has responded to firms’ questions on how the Money Laundering Regulations interact with the UK’s new cryptoassets framework. In the US, stablecoin issuers face bank-like AML/CFT and sanctions obligations under the GENIUS Act proposals, while in Dubai, VARA has tightened due diligence expectations for virtual asset service providers. At international level, the FATF has published a targeted report on regulatory challenges arising from DeFi.
What this means for cross-border firms
Firms active in both the EU and the UK will need to reconcile a harmonised EU rulebook with a distinct and evolving UK regime. Groups operating in six or more Member States should assess now whether they may fall within AMLA’s direct supervision. US-facing investment advisers should use the time before 2028 to build their programmes, and stablecoin issuers should prepare for the GENIUS Act requirements. Branches of foreign banks in the UAE should test whether home-country programmes meet local expectations, given the personal liability now facing compliance officers. Reviewing group-wide policies, due diligence processes and suspicious activity reporting against the emerging standards will help firms move from fragmented local compliance to a coherent, cross-border framework.
United Kingdom
UK Govt Policy Paper – Anti-money laundering and asset recovery strategy 2026–2029
On 16 September 2026, the UK Government issued a Policy Paper concerning its anti-money laundering and asset recovery strategy 2026–2029. Read our update here.
FCA multi-firm review on money mules
On 23 September 2026, the Financial Conduct Authority (FCA) published its findings following a multi-firm review into money mule activity. Read our update here.
European Union
AMLA Executive Board Member Simonas Krepšta addresses Global Conference on Criminal Finances and Cryptoassets in Luxembourg
On 15 September 2026, EU Anti-Money Laundering Authority Executive Board Member Simonas Krepšta delivered a presentation at the 10th Global Conference on Criminal Finances and Cryptoassets in Luxembourg on 15 September 2026, setting out AMLA’s priorities on crypto assets. The conference was hosted by the Basel Institute on Governance, Europol and the UNODC. Further information is here.
France
There have been no reported updates this month.
Netherlands
AFM update on AML compliance by fund managers
On 15 September 2026, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published a news update on the compliance of investment fund managers with the Dutch Act on the prevention of money laundering and terrorism financing (Wet ter voorkoming van witwassen en financieren van terrorisme, Wwft) and the Dutch Sanctions Act 1977 (Sanctiewet 1977,Sw). Read our update here.
UAE
There have been no reported updates this month.
Australia
Law Society seeks to address practical consequences of AML/CTF reforms
At the request of the Law Council and following the commencement of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime on 1 July 2026, the Law Society consulted with Members and relevant Committees to compile a list of outstanding AML/CTF issues and queries from South Australian lawyers and law firms, to direct the Law Council’s future advocacy. Further information is here.
United States
There have been no reported updates this month.
International regulators – FATF and Wolfsberg Group
FATF Mutual Evaluation Report of Türkiye 2026
On 23 September 2026 the Financial Action Task Force (FATF) published its mutual evaluation of Türkiye which assessed the effectiveness of the country’s measures against money laundering, countering terrorist financing and proliferation financing, and the level of compliance with the FATF Recommendations, at the time of its on-site visit in November 2025. Further information is here.
Risks of Gaming and Gambling
On 9 September 2026, FATF published new risk indicators to help governments, regulators and private sector entities identify and respond to money laundering, terrorist financing and proliferation financing risks in the rapidly evolving gaming and gambling sectors. Further information is here.
Investigating Professional Money Laundering, Underground Banking, and the Use of Hawala and Other Similar Service Providers
On 3 September 2026 FATF issued a report which examines the roles, methods and typologies of underground banking and hawala, and other similar service providers in professional money laundering, as well as the capabilities and responses of competent authorities to these phenomena. Further information is here.