Introduction

Financial services regulators, around the world are treating 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 therefore safeguards need to be highly responsive to localised risks. 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 October 2026 – 31 October 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 update focuses on legislative, regulatory and policy developments, including new rules, guidance, consultations and supervisory publications. It does not cover enforcement actions, fines or court cases.

This month’s highlight

Machines without borders: AI and cross-border AML compliance

Rules-based transaction monitoring generates large numbers of false positives while still missing sophisticated typologies. Machine-learning models can analyse richer data and detect anomalies across networks of accounts. The Financial Action Task Force has recognised that new technologies can make AML/CFT measures more effective if deployed responsibly. In the EU, the AML Regulation (Regulation (EU) 2024/1624, applying from 10 July 2027) and the new Anti-Money Laundering Authority (AMLA) are creating a single rulebook, making group-wide AI tools more realistic.

But harmonisation remains incomplete. Groups operating in the EU, the UK, the United States and Asia answer to multiple supervisors with divergent expectations, and a model calibrated for one jurisdiction may be poorly suited to another. Three issues dominate.

Data. Privacy, data protection and data localisation laws, together with banking secrecy and tipping-off rules, can limit what may be shared or pooled at group level. Firms must reconcile this with supervisors’ expectations of an enterprise-wide view of risk. Privacy-enhancing technologies such as federated learning allow models to learn from distributed data without centralising it.

Model risk and accountability. Supervisors will not accept “the model said so”. AI models used for monitoring, screening or customer risk rating fall squarely within supervisory expectations on model risk management: firms must document, validate and monitor them, and explain why alerts were raised or suppressed. Senior managers remain personally accountable for the effectiveness of AML systems and controls, and meaningful human review is essential. Opaque models that disproportionately flag particular communities also risk unfair customer outcomes and financial exclusion.

Evolving regulatory frameworks. Approaches to AI range from dedicated legislation to principles-based guidance. Financial supervisors are also applying existing rules on governance, outsourcing, third-party risk and operational resilience to AI tools. A single group-wide system may therefore need to satisfy several overlapping regimes and supervisors at once.

Firms should:

  • Map each AI use case against the AML, data and AI requirements of every relevant jurisdiction.
  • Embed AI in model risk management, with validation, bias testing and ongoing monitoring.
  • Assign clear senior management responsibility and board-level oversight.
  • Maintain audit trails so that decisions can be reconstructed for supervisors.
  • Define the authority of human reviewers to escalate and override outputs.
  • Treat AI vendors as material third parties, with audit rights and exit plans.
  • Engage early with supervisors, including through innovation hubs and sandboxes.

AI can make AML compliance more effective in a world where illicit finance ignores borders, but it redistributes rather than removes regulatory responsibility. Successful firms will govern AI through clear accountability, quality data and an understanding of each supervisor’s expectations. As the EU single rulebook takes shape and AI regulation matures, now is the time to build frameworks that withstand supervisory scrutiny across borders.

United Kingdom

There have been no reported updates this month.

European Union

On 1 October 2026, the Anti-Money Laundering Authority (AMLA) issued a Final Report on draft Regulatory Technical Standards (RTS) on the respective duties of the home and host supervisors, and the modalities of cooperation between them under Article 46(4) of the Sixth Anti-Money Laundering Directive. Further information is here.

AMLA consults on draft RTS for AML/CFT central database

On 7 October 2026, the AMLA issued a consultation paper on draft RTS on the anti-money laundering / countering the financing of terrorism central database under Article 11(6) of the AMLA Regulation (Regulation (EU)2024/1620). Further information is here.

France

2025 key figures for FIAs

On 12 October 2026, the AMF issued a report providing a summary of quantitative and qualitative information relating to financial investment advisers for the year 2025. In particular, it presents the main activity indicators, the distribution of actors by professional associations and their specificities. A dedicated AML/CFT section in the report restates the AMF’s sector risk assessment of June 2024. That assessment rated advisers’ overall risk as moderate for money laundering and low for terrorist financing. The report is here.

Netherlands

AFM alert – AMLA publishes technical standards for CDD, business relationship and group-wide requirements

On 1 October 2026, the AFM issued an alertreporting that AMLA had published regulatory technical standards under the new Anti-Money Laundering Regulation. They cover customer due diligence, business relationships and group-wide controls. The AFM encourages firms to use them to assess the impact and start adapting early to the new EU rules. The alert is here.

DNB & AFM Sanction Alert – State of affairs September 2026

On 12 October 2026, DNB and the AFM issued a news release covering the period from 1 September 2026 to 30 September 2026. During this period, there have been changes to the sanctions regimes relating to the Terrorism Sanctions Regime 2007-II, Russia and Ukraine, Burundi, the Democratic Republic of Congo, Afghanistan and ISIS and Al-Qaeda. The new release is here.

UAE

There have been no reported updates this month.

Australia

There have been no reported updates this month.

United States

FinCEN announces withdrawals of proposed digital asset related rules

On 5 October 2026, Financial Crimes Enforcement Network (FinCEN) withdrew the following proposed rules that would have imposed certain regulatory requirements on financial institutions related to certain digital assets, specifically convertible virtual currencies:      

  • A proposal that would have imposed recordkeeping, verification, and reporting requirements on certain transactions involving convertible virtual currencies and unhosted wallets.
  • A proposal that would have imposed a special measure with regards to convertible virtual currency mixing.

FinCEN has considered the comments submitted in response to these proposals and is withdrawing them as part of the Trump Administration’s deregulatory agenda and ongoing efforts to ensure digital asset regulations are fit-for-purpose.

The announcement is here.

International regulators – FATF and Wolfsberg Group

Outcomes FATF Plenary October 2026

On 30 October 2026, the inaugural FATF Plenary meeting under the UK Presidency of Giles Thomson concluded, with countries agreeing global action to tackle evolving financial crime threats, including the rising threat posed by virtual assets, fraud and scam compounds.

In response to the FATF Ministerial Declaration of April 2026, the Plenary agreed to significantly accelerate the effective implementation of the FATF Standards on virtual assets (VAs) in jurisdictions with materially important VA activity. The Plenary recognised the need to urgently strengthen countries’ defences against the rising threat posed by the misuse of VAs for money laundering, terrorist financing and proliferation financing.

The Plenary agreed to launch a new targeted review and accelerated follow-up processes, to support jurisdictions to address gaps in implementation of the FATF Standards on VAs and virtual asset service providers more rapidly.

The Plenary adopted reports of Mexico and the United States under the new round of mutual evaluations.

The FATF agreed to remove Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco from its list of jurisdictions under increased monitoring following successful on-site visits, and the FATF updated its statements on jurisdictions under increased monitoring and jurisdictions subject to a call for action.

The report is here.

FATF updates lists of high-risk jurisdictions and jurisdictions under increased monitoring

On 30 October 2026, the FATF published updated lists of high-risk jurisdictions subject to a call for action and jurisdictions under increased monitoring. The updates are here and here.