EMEA AML Survey 2026

Anti‑money laundering (AML) efforts across the EMEA region have entered a new phase of complexity, driven by evolving financial crime risks, geopolitical instability, and accelerating digitalisation. Criminals are increasingly exploiting regulatory fragmentation and uneven levels of supervisory intensity.

In the EU, the recently adopted AML Package, introducing a single rulebook, a new directive and an EU‑level supervisory authority, represents the most far‑reaching AML overhaul to date. While regulatory ambition is clear, implementation poses significant operational, technological, and organisational challenges for financial institutions.

Beyond the EU, a widening regulatory gap is emerging as several jurisdictions continue to operate under less prescriptive frameworks. In parallel, the US is signalling a softening of enforcement priorities. This growing divergence heightens the risk of regulatory arbitrage and places disproportionate strain on institutions operating across multiple regimes.

PwC’s second EMEA AML Survey builds on our inaugural 2024 study and captures perspectives from 522 financial institutions across the EMEA region, including banks, asset and wealth managers, electronic payments firms, crypto‑asset service providers and virtual asset firms.

This edition broadens its scope with the inclusion of insurance companies for the first time, providing new insights into a sector facing some of the steepest compliance pressures.

As an additional feature, a sample of 12 US financial institutions was surveyed. The findings are presented across three dedicated thematic boxes throughout the report, offering a first transatlantic comparison and highlighting growing regulatory divergence between major global regions.

The survey sheds light on both areas of progress and persistent structural challenges, from regulatory effectiveness and rising compliance costs to investments in controls, technology, talent and AML digital transformation. It ultimately aims to support financial institutions and policymakers in building AML frameworks that are more robust, effective and fit for purpose. 

AML compliance costs continue to surge, with roughly one-third of all institutions expecting a 10–30% rise over the next two years and up to 40% of EU respondents attributing this directly to the AML Package, while 42% of US respondents expect costs to decrease, underlining a stark transatlantic gap. Within the EU, the AML Package is the most consequential reform in over a decade, yet fewer than 30% of institutions have completed both a detailed analysis and impact assessment, and only about one-third expect to be compliant by the July 2027 deadline, with AMLA's first reporting exercise, launched in March 2026, already revealing significant data and process gaps. Beyond the EU, the regulatory divide is widening fast: fewer than 12% of non-EU institutions now believe current AML rules are effective, down from three to five times higher in 2024, while none of the surveyed US institutions consider their rules effective, suggesting a growing "contrast effect" as the EU AML Package resets expectations of what good regulation looks like. Operating consistently across multiple regimes is rapidly becoming a core competitive differentiator.

Have you already done a detailed analysis of the practical implications of the new EU AML Package? (by type of respondent) (EU respondents)

^{Source: PwC Global AWM & ESG Research Centre
Note: Question asked to respondents from the EU and subject to EU Directives and Regulations. The percentages may not add up to 100% due to rounding.} 

Customer Due Diligence has emerged as the single largest operational bottleneck: a clear majority of EU respondents consider the draft RTS data requirements excessive, more than 40% fear the approach is overly rules-based, very few believe their procedures are fully aligned, and around 60% plan to reallocate internal resources for CDD remediation, yet most intend to handle this in-house despite persistent talent shortages, with up to 35% of institutions struggling to recruit qualified staff and up to 22% expecting to lose people to AMLA itself. Confidence in transaction monitoring has roughly halved since 2024, dropping from as high as 75% to below 30%, prompting close to half of respondents to plan group-level or local reviews within 24 months. A critical blind spot persists around document authenticity, where the vast majority still lack an AI-driven verification tool, while the new five-year maximum KYC review cycle for low-risk customers will add further operational pressure. Outsourcing is rising as a coping mechanism, particularly for periodic KYC reviews and screening, as the combination of regulatory demands, limited talent and cost pressures forces institutions to fundamentally rethink their operating models.

Are you confident that your transactions monitoring is fit for purpose? (all respondents)

^{Source: PwC Global AWM & ESG Research Centre
Note: Question asked to all respondents. The percentages may not add up to 100% due to rounding.}

The erosion of confidence in existing controls is triggering a wave of targeted technology investment, with more than half of institutions planning to introduce new technologies for transaction monitoring or CDD within 24 months, while GenAI, AI/ML and Agentic AI are all on the agenda, though appetite varies widely, with nearly half of insurance companies not considering any form of AI. Yet data quality (the #1 blocker in 2024) remains firmly in that position in 2026, cited by up to 89% of respondents as the top barrier to AI adoption, and AMLA's first reporting exercise has confirmed that many institutions still struggle to understand what data must be provided and how to generate it. More than a third of respondents expect to make significant changes to their data structures, pointing to large-scale transformations rather than incremental fixes. Cloud maturity is also emerging as a differentiator: while 60% of US respondents have already invested in cloud for their AML tools, the majority across EMEA have not, and without foundational improvements in data and infrastructure, the ambitions around both technology and regulatory compliance risk falling short.

Are you considering implementing AI in your AML processes/workflows? (all respondents)

^{Source: PwC Global AWM & ESG Research Centre
Note: Question asked to all respondents. The percentages may not add up to 100% due to rounding.}

PwC has created an AML benchmarking tool that allows organisations to compare their AML practices to the overall market trends. Users can now see how their industry and national peers are reacting to specific provisions and articles of the EU AML Package, as well the operational and technological trends that are developing across EMEA.

• Insights can be tailor-made to compare organisations to their peers at the national or regional levels, as well as within or across industries.
• Since the benchmarking tool includes the 2024 and 2026 survey data, organisations can see how trends have developed over time.
• PwC can provide bespoke presentations to executive boards. If they have not participated in the AML survey yet, they can be benchmarked to provide the most accurate results.

Please reach out to us to programme a customised benchmarking session.