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“The CEE edition of the EMEA Anti-money laundering (AML) Survey shows that financial institutions in the CEE region benefit from the wealth of talent available to help organisations tackle financial crime. This favourable situation likely stems from a high concentration of Global Business Service centres in the region, and serves as training grounds for professionals — equipping them with knowledge and expertise in AML and other compliance areas.
Many financial institutions in the CEE region are committed to adopting advanced technological infrastructure and most are willing to invest a significant portion of their budgets on new technologies. The data shows that CEE financial institutions are keen on integrating AI into their AML models at a much higher rate than certain regions in Western Europe. Nevertheless, companies adopting AI need to assess and manage the wide array of risks new technologies might pose enterprise-wide — including any regulatory developments related to the use of AI.”
EMEA AML Survey 2024 — highlights
The Europe, Middle East, and Africa (EMEA) AML Survey 2024 highlights several key insights and challenges faced by financial institutions in the EMEA region concerning AML practices:
The increase in regulatory pressure is a significant challenge and regulations can complicate operational processes.
Perceptions of effectiveness of current regulation are split among financial institutions, with banks finding them less effective than payment institutions or asset managers.
Within the European Union (EU), only slightly more than half of respondents welcome the upcoming EU AML Package and consider current regulations sufficiently clear and fit for purpose.
More than half of respondents have seen their AML compliance costs rise by over 10% in the last two years. Banks report that the largest contributors to increased AML compliance costs are hiring additional staff and investing in new digital tools.
For financial institutions finding skilled employees who understand operations and can lead the implementation of new technologies effectively is critical for effective AML compliance. Upskilling existing employees is also likely to be a major investment driver in the coming years.
The CEE edition of the EMEA AML Survey 2024—key takeaways
Financial institutions in the Central Eastern Europe (CEE) region face similar challenges to those elsewhere in EMEA. Perhaps unsurprisingly, however, significant differences are also noted:
- EU respondents in the CEE region find the current and upcoming regulatory environment less effective than their counterparts in a broader EMEA region, primarily due to inconsistent standards and a lack of practical guidance.
Both regions face similar AML challenges, such as regulatory pressure and operational complications.
The broader EMEA region struggles more with staffing, whereas the CEE region faces difficulties in retaining talent due to growing remuneration pressure.
- CEE financial institutions, overall, consider staff upskilling less critical than those elsewhere in the EMEA region. This can be attributed to their experience in leveraging existing talent acquired through business process outsourcing and managed services.
Transaction monitoring is perceived as the least effective AML control in the CEE region, suggesting a need for further development in this area. Transaction monitoring is, however, ranked as more effective by the majority of the EMEA region financial institutions, and remains a top investment priority in both the CEE region and the broader EMEA region.
- The majority of CEE financial institutions reported increased AML compliance costs—influenced by inflation, salary hikes, and tech investments.
The average increase in compliance costs was higher than the majority reported by EMEA financial institutions. CEE financial institutions plan to allocate a significant proportion of their budgets, over 10%, to new technologies.
The Benelux, UK & Ireland and Germany, Austria and Switzerland (DACH) regions within the EMEA region are less willing to invest in new technologies.
The survey suggests that technological investments are proving beneficial for CEE institutions, with fewer of them citing outdated systems as a barrier compared to EMEA averages.
The CEE region shows higher adoption rates of know your customer (KYC) digital tools and artificial intelligence (AI) solutions. These tools are particularly used in transaction monitoring, screening, customer due diligence, and risk assessment, underscoring a strong commitment to leveraging advanced technologies for robust AML practices.
Divergence between CEE and EMEA regions
AML Regulations
Outlook on regulation
Financial institutions in the CEE region find current and upcoming AML rules largely unhelpful, with only 43% of respondents considering both of them fully effective. In contrast, institutions in the broader EMEA region exhibit more confidence in both current (56%) and upcoming (54%) regulations. More granular industry views in the CEE region show similar percentages: slightly less than 40% of banks believe that current and upcoming regulations are effective, while payment institutions are more optimistic, with 75% viewing both sets of regulations as effective.
The primary issue identified by CEE financial institutions in the current regulations is the lack of uniform standards across countries and industries (18%).
Regarding upcoming regulations, 25% of CEE respondents cite a lack of practical guidance as their biggest concern. The CEE region and the broader EMEA region agree that the main challenge posed by current rules is the lack of uniform standards. However, financial institutions in the broader EMEA region are less concerned about the lack of practical guidance for upcoming rules (12%) and continue to point to the lack of uniformity across countries and industries (19%) as the major issue for forthcoming regulations.
AML Challenges
CEE responses on the principal AML challenges broadly align with those from the broader EMEA region. They both identify increased regulatory pressure (38% in CEE vs. 38% in EMEA), data management and quality (36% in CEE vs. 34% in EMEA) and regulations complicating operational processes (36% in CEE vs. 34% in EMEA) as the most challenging domains.
The most significant difference was observed in staffing challenges, which were not seen as a major issue in the CEE region, with only 7% identifying it as a problem, compared to the rest of the EMEA region where 24% of financial institutions cited staffing as a significant issue.
By industry breakdown, similar conclusions are reached with a very low percentage of CEE banks and no payment institutions reporting staffing challenges. A large portion of CEE and EMEA respondents expressed an interest in increasing staff levels (72% in EMEA vs. 67% in CEE). In contrast to the rest of the EMEA region responses, CEE financial institutions do not plan to decrease staff levels. Interestingly, a higher percentage of CEE financial institutions (41%) identified 'salary package' as the primary obstacle to retaining AML and combating the financing of terrorism (CFT) talent compared to the broader EMEA region (31%).
This indicates that, although experts and specialists are available in the CEE market, there is a rising expectation for higher salaries. This pattern is being driven by rising inflation and the more general trend of salaries converging with Western European levels.
AML Operations
Effectiveness of AML controls
There are noticeable differences in how the CEE region perceives the effectiveness of their AML controls compared to Western Europe. In the broader EMEA region, upskilling is seen overall as the strongest AML control by the majority of respondents. Notable differences are reported in the DACH and CEE regions, where the lowest percentage of respondents ranked upskilling as the strongest AML control. Banks in the CEE region also consider upskilling one of the least effective controls, aligning with the views of banks in the broader EMEA region.
Exhibit 1: Respondents who state that recruiting skilled staff is one of the biggest challenges to AML – Regional breakdown
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EMEA AML Survey 2024 - CEE Edition
About the Survey
The CEE Edition of the EMEA AML Survey 2024
This survey is based on the EMEA AML Survey 2024, published in April 2024, and covers responses from financial institutions based in the CEE region. In the CEE region we have a presence in 53 offices across 27 countries.
A total of 39 financial institutions from the CEE region participated in the survey, representing 10% of all EMEA respondents. Among these CEE respondents, 88% were banks, and 12% were payment institutions, with 77% of the respondents being based in the European Union.
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