On 10 August 2023, the European Banking Authority (EBA) published a report on the functioning of anti-money laundering and countering the financing of terrorism (AML/CFT) colleges in 2022.

The EBA has been monitoring AML/CFT colleges since their inception and has published previous AML/CFT colleges monitoring reports in 2021 and 2022.

Through 2022, EBA staff actively monitored 16 of the AML/CFT colleges and carried out a thematic review of 10 investment colleges. EBA staff also collected data on all AML/CFT colleges to assess their performance against the six action points that the EBA issued in 2022 to address the findings of its previous report on AML/CFT colleges.

The EBA found that Member State competent authorities had taken important steps to make AML/CFT colleges useful and effective. A structured approach to organising colleges’ meetings had contributed to the exchange of more substantive, actionable information, than was the case previously, and prudential supervisors and financial intelligence units (FIUs) had actively participated in most AML/CFT colleges, to which they had been invited.

In several colleges, the quality of discussions was greatly enhanced, and the lead supervisor was leading these discussions much more effectively. A small number of colleges had taken coordinated actions to address areas of common concern with good outcomes.

Nevertheless, the report notes that none of the 2022 action points have been fully addressed by all colleges and, in particular, EBA staff observed that:

• More than 50 AML/CFT colleges which had been set up pursuant to the ‘Guidelines on cooperation and information exchange for the purpose of Directive (EU) 2015/849 between competent authorities supervising credit and financial institutions’ were still not operating, and members’ ability to share information in some colleges was hampered by their failure to sign the requisite cooperation agreements.
• The number of third country observers remained very low, which could limit what supervisors know about group-wide risks.
• There was limited awareness among some Member State competent authority staff of the benefits of sharing information in the colleges’ setting and some Member State competent authorities were unable to explain how they used information from AML/CFT colleges in their own work. Common approaches or coordinated actions were rarely envisaged or discussed because members did not determine whether the issues identified had a common root cause.
• Several lead supervisors had not adjusted the nature and frequency of meetings based on money laundering/terrorist financing risks to which the financial institution had been exposed. This meant that some high-risk colleges met infrequently, while colleges set up in relation to lower risk institutions met at least biannually.

Based on these findings, the action points adopted in 2022 remain relevant for the 2023-2024 period. Lead supervisors should address them without delay to make the best use of the AML/CFT colleges framework.