Global Watchdogs and the Future of AML/CFT Compliance: How JTC Supports Clients Through Regulatory Change

The European regulatory landscape continues to evolve rapidly, and this year’s European Anti-Financial Crime Summit, hosted by AML Intelligence in Dublin, again highlighted the pace and direction of that change.

In keeping with JTC’s proactive approach to regulatory developments impacting our clients, Clay Dupuy, Director, MLRO Services and Charlotte Ryan, Senior Manager, MLRO Services, attended the summit to gain first-hand insight into emerging priorities across the anti-financial crime framework.

FATF

A key takeaway was the opportunity to hear from FATF President Elisa de Anda Madrazo on the forthcoming fifth round of FATF mutual evaluations and the continued emphasis on a more risk-based and proportionate approach to FATF’s monitoring processes. Commencing in 2024 under the revised 2022 methodology, the fifth-round places emphasis not only on technical compliance, but also on a jurisdiction’s risk profile, the relative scale of its economy and financial sector and the overall effectiveness of its AML/CFT/CPF framework.

In that context, the discussion underscored FATF’s increasing focus on the most material risks from a global perspective, while recognising that jurisdictions do not all begin from the same baseline and may differ in their capacity to implement the FATF 40 Recommendations at the same pace. It was also suggested that, consistent with this more calibrated and outcomes-focused approach, FATF may be less inclined than in previous rounds to move jurisdictions onto the grey list solely on the basis of technical deficiencies, particularly where those deficiencies do not point to more significant weaknesses in the overall effectiveness of the AML/CFT/CPF framework.

For jurisdictions with mutual evaluations on the horizon, including Ireland and the Cayman Islands, this is especially relevant as Ireland’s visit is anticipated and the Cayman Islands’ is scheduled for 2027 under this more risk-sensitive framework.

Central Bank of Ireland

Patricia Dunne, Director of Horizontal Supervision at the Central Bank of Ireland (CBI), also addressed the summit and spoke to the CBI’s Regulatory & Supervisory Outlook 2026.

For Irish funds and their MLROs, the message is clear: supervisory expectations continue to rise across governance, delegation, outsourcing, operational resilience, AML/CFT, valuation, liquidity risk and AI. In the funds sector specifically, the CBI continues to highlight the scale, complexity and international reach of the industry, with ongoing focus on governance substance, oversight of delegated models, DORA implementation, valuation of hard-to-value assets and liquidity and leverage risk management.

From a financial crime perspective, the CBI’s Regulatory & Supervisory Outlook 2026 is particularly relevant for MLROs. The CBI expressly notes that the Irish funds sector remains under international scrutiny from an AML/CFT perspective because of its size and reach and it signals direct supervisory attention on enhanced AML/CFT risk data, transaction monitoring and STR reporting. This means firms should be able to demonstrate not just documented frameworks, but effective oversight of outsourced AML operations, strong escalation processes, reliable data and meaningful governance challenge.

It is imperative that Irish funds do not view AML/CFT in isolation. The CBI is increasingly linking financial crime controls with broader expectations around governance, operational resilience, data quality and investor protection. Funds that can evidence joined-up oversight across these areas, supported by their MLRO, will be better placed for the supervisory focus ahead.

AMLA

Lastly, Tony Cahalan, Ireland’s alternate member of the Anti-Money Laundering Authority (AMLA), noted that AMLA remains focused on three core priorities:

1. promoting a more harmonised EU-wide AML/CFT framework through the new single rulebook;
2. fostering closer and more effective cooperation between firms, national supervisors and other competent authorities and
3. preparing for the direct supervision, from 2028, of up to 40 of the EU’s most significant and higher-risk cross-border financial institutions.

Throughout his industry briefing, Mr. Cahalan emphasised the importance of ensuring that supervision across the EU is both consistent and genuinely risk-based, with proportionate measures applied considering the nature, scale and complexity of individual firms. He also highlighted the need for clearer supervisory expectations and more practical guidance for industry, particularly as firms prepare for a more centralised and convergent European framework.

In addition, he pointed to the increasing importance of innovation and technology, both for public authorities and the private sector, not only to support compliance with evolving regulatory requirements, but, more importantly, to strengthen the detection and prevention of the financial crime risks most relevant to their jurisdictions.

Mr. Cahalan also identified implementation timing as one of AMLA’s principal near-term challenges. While the EU’s new AML/CFT legislative package entered into force in 2024, much of the framework will apply on a phased basis over the coming years. In particular, the new AML Regulation, which forms a central part of the single rulebook, entered into force in July 2024 and will apply from 10 July 2027.

In parallel, AMLA is already laying the groundwork for its direct supervisory role, including developing the methodology and data collection processes that will underpin the 2027 selection of firms for direct supervision beginning in 2028. Against that backdrop, the message from Mr. Cahalan was that the immediate priority is not simply legislative completion but ensuring that the new framework is operationalised in a way that delivers more coherent, effective and proportionate supervision across the Union.

What Does This Mean for Your Business?

The direction of travel is clear: AML/CFT expectations are becoming more risk-based, more data-driven and more focused on demonstrable outcomes. Firms should expect closer scrutiny of governance, risk assessments, transaction monitoring, reporting, and oversight of outsourced or delegated arrangements.

For businesses, AML/CFT compliance is no longer a standalone exercise. It must be embedded across governance, operations and risk management, with clear accountability, reliable data and effective controls. As EU rules become more harmonised and supervisory expectations continue to rise, firms need to be ready to evidence not just compliance, but effectiveness.

How JTC Supports Clients Through AML/CFT Regulatory Change

JTC helps clients respond to this evolving landscape with practical, proportionate and expert support. Our specialist teams work with firms to strengthen AML/CFT frameworks, enhance governance and oversight, and stay ahead of regulatory change.

Our services include:

• MLRO/RC solutions: experienced internal and external MLRO and RC support tailored to your business
• AML/CFT frameworks: design, implementation and enhancement of policies, procedures and controls
• CDD and EDD services: onboarding, monitoring, beneficial ownership analysis, screening and record-keeping
• Risk assessments and training: practical support to identify, manage and evidence financial crime risk
• Regulatory change support: helping firms prepare for new rules, guidance and supervisory expectations

Partner with JTC

In a more demanding regulatory environment, firms need more than technical advice; they need a partner that can deliver practical implementation and ongoing support. JTC combines deep regulatory expertise, operational experience and technology-enabled solutions to help clients manage AML/CFT risk with confidence.

Contact our Regulatory Services team to discuss how we can support your AML/CFT, CDD, MLRO or RC requirements.