Policy brief

A better European Union architecture to fight money laundering

A series of banking scandals in multiple EU countries has underlined the shortcomings of Europe's anti-money laundering regime. The impact of these sh

Publishing date
25 October 2018

A series of banking scandals in multiple European Union countries including Cyprus, Denmark, Estonia, Latvia, Malta, the Netherlands and the United Kingdom has underlined the shortcomings of the European Union’s anti-money laundering (AML) regime. Many of these cases have involved staggering sums, with billions of dollars laundered through accounts at one bank. The impact of the EU’s AML shortcomings has been further underlined by changing geopolitics and by the new reality of European banking union.

The EU legal framework combines a strong, enforceable single market with national AML supervision of banks and other financial and non-financial firms in which the mechanisms to ensure EU-wide supervisory consistency are insufficient. This combination fosters a vicious circle of erosion of supervisory effectiveness in those member states where money launderers tend to concentrate their activity, which undermines the integrity of the entire European system.

The imperative of establishing sound supervisory incentives to fight illicit finance effectively demands a stronger EU-level role in AML supervision. We recommend a unitary architecture centred on a new European AML Authority that would work on the basis of deep relationships with national authorities such as financial intelligence units and law enforcement agencies. The new authority should have high standards of governance and independence, publish all its decisions and be empowered to impose sufficiently large fines to deter malpractice. It would also act as a catalyst for further EU harmonisation of the AML legal regime.

About the authors

  • Nicolas Véron

    Nicolas Véron is a senior fellow at Bruegel and at the Peterson Institute for International Economics in Washington, DC. His research is mostly about financial systems and financial reform around the world, including global financial regulatory initiatives and current developments in the European Union. He was a cofounder of Bruegel starting in 2002, initially focusing on Bruegel’s design, operational start-up and development, then on policy research since 2006-07. He joined the Peterson Institute in 2009 and divides his time between the US and Europe.

    Véron has authored or co-authored numerous policy papers that include banking supervision and crisis management, financial reporting, the Eurozone policy framework, and economic nationalism. He has testified repeatedly in front of committees of the European Parliament, national parliaments in several EU member states, and US Congress. His publications also include Smoke & Mirrors, Inc.: Accounting for Capitalism, a book on accounting standards and practices (Cornell University Press, 2006), and several books in French.

    His prior experience includes working for Saint-Gobain in Berlin and Rothschilds in Paris in the early 1990s; economic aide to the Prefect in Lille (1995-97); corporate adviser to France’s Labour Minister (1997-2000); and chief financial officer of MultiMania / Lycos France, a publicly-listed online media company (2000-2002). From 2002 to 2009 he also operated an independent Paris-based financial consultancy.

    Véron is a board member of the derivatives arm (Global Trade Repository) of the Depositary Trust and Clearing Corporation (DTCC), a financial infrastructure company that operates globally on a not-for-profit basis. A French citizen born in 1971, he has a quantitative background as a graduate from Ecole Polytechnique (1992) and Ecole Nationale Supérieure des Mines de Paris (1995). He is trilingual in English, French and Spanish, and has fluent understanding of German and Italian.

    In September 2012, Bloomberg Markets included Véron in its second annual 50 Most Influential list with reference to his early advocacy of European banking union.


  • Joshua Kirschenbaum

    Joshua Kirschenbaum is a senior fellow at GMF’s Alliance for Securing Democracy, focusing on illicit finance. Josh joined GMF from the Treasury Department, where he worked from 2011 to 2018. He served as acting director of the Office of Special Measures at Treasury’s Financial Crimes Enforcement Network, overseeing international money laundering investigations under Section 311 of the USA PATRIOT Act. Previously, Josh worked on Iran sanctions at Treasury’s Office of Foreign Assets Control (OFAC). In 2019, he became a Senior Vice President in the Bank Secrecy Act / OFAC Department at the Bank of Hope, a regional bank based in Los Angeles. The views expressed are solely his and do not purport to reflect the views of his employer.

    He received a master’s degree in international security from Georgetown University and a bachelor’s degree in public policy from Northwestern University.

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