This formal submission from the Global Coalition to Fight Financial Crime (GCFFC), addressed to Mrs. Bruna Szego, Chair of the Anti-Money Laundering Authority (AMLA), serves as a strategic response to AMLA's 2026-2028 Single Programming Document (SPD). As supervisory responsibilities transitioned to AMLA on 31 December 2025, the GCFFC underscores the necessity of a unified approach to combat the cross-border and evolving nature of illicit finance.

The GCFFC fully supports AMLA’s mandate to strengthen supervisory coherence and reduce fragmentation across the EU. However, the letter highlights a critical dependency for the success of this mission: the urgent need for supervisory convergence between AMLA, the European Data Protection Board (EDPB), and national authorities. The GCFFC warns that without legal clarity and certainty on data processing and information sharing, regulatory gaps will persist, allowing criminals to exploit GDPR provisions and posing systemic risks to the Union.

Core Recommendations for a Data-Driven Framework

To move beyond a rules-based approach toward an outcomes-focused model, the GCFFC proposes several primary actions:

• Establish Lawful Bases for Processing: Clearer definitions are needed for when data processing relies on legal obligations (Article 6(1)(c)) versus legitimate interests (Article 6(1)(f)), particularly regarding global sanctions.

• Enable Proportionate Information Sharing: The GCFFC advocates for structured Partnerships for Information Sharing (PFIS) that fuse public intelligence with private-sector data. These partnerships are essential for detecting complex, layered networks that no single institution can identify alone.

• Harmonize Regulatory Principles: AML/CFT obligations must be reconciled with GDPR principles such as data minimization and purpose limitation to avoid "regulatory whiplash" or de-risking.

The GCFFC notes that despite extensive investment, less than 1% of global illicit flows are currently seized. Under the FATF’s revised methodology, Europe’s success will be judged by its real-world results—its "effectiveness"—rather than just its rules on paper.

If Europe's AML/CFT system is viewed as operationally complex, legally contested, or fragmented by inconsistent data-protection interpretations, the EU risks being perceived as a "financial crime risk region". Such a reputation could lead to tougher due diligence expectations from global counterparties and reduced confidence in cross-border intelligence sharing.

The GCFFC stands ready to assist AMLA in building a resilient anti-financial crime framework that protects both the integrity of the financial system and the fundamental rights of its citizens. By incorporating the EDPB into the AML/CFT community, AMLA can ensure that harmonized standards for financial security and data protection are developed in parallel, closing the seams that criminals currently exploit.

Full letter below