Webinar: AMLA: The system rebuild has started

Europe is preparing to transform how it fights financial crime, not by tightening existing rules, but by rebuilding the system itself.

In our recent webinar, Beyond Directives: The Structural Shift to AMLA, we explored what this shift really means in practice. The conclusion is unambiguous: the EU’s new Anti-Money Laundering Authority (AMLA) is not a regulatory update. It is a structural reset of how compliance operates across Europe.

A System Under Strain

The scale of the problem is well known, but still underappreciated. Around €2 trillion is laundered through Europe each year, often through systems designed to prevent it. Recent cases, from Danske Bank to Wirecard and NatWest, reveal a consistent pattern. Different institutions, different failures, but a shared root cause: a fragmented framework built on documents, duplication and limited coordination. Responsibility is often distributed across jurisdictions, while accountability is not.

Today’s model remains largely manual. Firms collect information directly from clients, store it in PDFs or spreadsheets, and revisit it periodically. The same investor can be onboarded multiple times by different institutions, each repeating the same checks, often with limited visibility into what others have already verified. Audit trails are frequently incomplete. Data is unstructured and dispersed across systems. Supervisors, when they investigate must reconstruct decisions after the fact, often with partial information. The functions of the system are inefficient, which are tolerated and its limitations are managed, rather than being resolved.

From Fragmentation to Systemic Oversight

AMLA changes this at a structural level. For the first time, the EU will operate under a single authority with the power to supervise, coordinate and enforce AML rules across all 27 member states. The long-standing inconsistencies between national regimes, which have allowed regulatory arbitrage and operational gaps, will narrow significantly. But the deeper transformation is not institutional, it is operational. AMLA introduces a model where compliance is no longer episodic or local, but continuous and system-wide. Reporting becomes structured and comparable. Supervisory visibility becomes real-time rather than retrospective. The ability to demonstrate compliance moves from narrative explanation to data-driven evidence. In this environment, firms are no longer simply expected to follow rules. They are expected to prove, at any moment, that those rules have been applied correctly.

The End of the Document-Centric Model

At the heart of this transition is a fundamental shift away from documents as the primary source of truth. Under AMLA, verification increasingly relies on data that is independently sourced, structured and capable of being cross-referenced across institutions and jurisdictions. Documents do not disappear, but their role changes. They move from being the foundation of compliance to supporting evidence within a broader data ecosystem. What matters is no longer what a document says, but where the underlying data comes from, how it is validated, and whether it can be compared and traced across systems. This has immediate implications. Firms must be able to map full beneficial ownership chains, not partially or on request, but continuously. They must maintain audit trails that capture not only outcomes, but the reasoning behind decisions. And they must ensure that those decisions can be replayed, in full, when challenged by a supervisor.

As discussed during the session, this represents a shift from a document-centric model to a data-centric infrastructure, one designed to support scale, interoperability and regulatory scrutiny.

An Infrastructure Challenge Disguised as Regulation

AMLA is often described as a regulatory reform. In practice, it is closer to an infrastructure transformation. The existing compliance architecture, which is built around manual processes, siloed systems and static records, was never designed for structured data, real-time monitoring or cross-border interoperability. Attempting to layer AMLA requirements onto this foundation will expose its limits quickly. The more accurate framing is that AMLA shifts compliance from a process problem to a data problem. The question is no longer whether a firm has performed the right checks, but whether it can demonstrate, through reliable and structured data, how and why those checks were performed. This distinction matters. Policies can be updated relatively quickly; infrastructure cannot.

A Narrow Window to Adapt

The practical implications are already clear. Firms will need to reduce reliance on client-provided documentation, integrate authoritative data sources such as registries, and build systems capable of producing clear, structured and auditable outputs in real time. Compliance workflows will need to be automated, interconnected and designed for scale. None of this can be achieved overnight. Rebuilding data architecture, integrating systems and redesigning workflows is a multi-year effort, often requiring organisational change as much as technological investment.

With AMLA set to take effect in July 2027, the timeline is already compressed. Firms that move early will not only meet regulatory expectations more comfortably; they will also gain operational advantages, including faster onboarding, reduced duplication and improved data quality. Those who delay will face the same transformation under tighter timelines and greater pressure.

AMLA does not ask firms to improve what they have. It assumes that what exists today will no longer be sufficient.

Overview of the webinar:

Watch the full webinar here (you need a Microsoft Teams account to access this)

Beyond AML: Innovation Drives Shaping the Future of Investment

The festive season is behind us, and we hope the year has started well for you, spent with family and friends.

Over the past few episodes, we have explored a wide range of topics across financial crime, regulation, onboarding, and documentation trust. In our most recent episode, we focused on documentation trust and examined the growing role of AI — discussing both its opportunities and its limitations, and how these may shape the investment industry in the years ahead.

In this new episode, we are joined by John Allan, Head of Innovation and Operations at The Investment Association, and a leading voice in shaping how the UK investment industry adapts to emerging technologies and regulatory change.

 

John is in conversation with Pierre-Yves Rahari, Co-Founder of Reseo, for a deep-dive into innovation in the investment management industry. Together, they explore the major forces currently reshaping the sector — from tokenisation and AI to operational resistance, fund modernisation, and the accelerating pace of change.

The discussion looks beyond theory to address how firms can navigate these shifts in practice, and what it really takes to apply innovation in real time.

Guest
John Allan, Head of Innovation & Operations, The Investment Association

Host
• Pierre-Yves Rahari, Co-Founder, Reseo

Producer & Editor
• Melanie Lopes, Sales & Marketing Associate, Reseo

Thanks for listening to the Reseo State of the Art podcast – you can find us here and on Spotify.

When Documents Can No Longer Be Trusted: Rebuilding AML/KYC in the Age of AI

In the latest episode of State of the Art, Reseo Co-Founders Pierre-Yves Rahari and Luuk Jacobs examine a challenge that is reshaping the foundations of financial crime prevention: the accelerating breakdown of trust in documents.

Across the investment industry, AML and KYC processes still rely heavily on documentation such as passports, certificates, corporate filings and identification records. Yet artificial intelligence is now making it possible to fabricate these documents with astonishing realism and at scale. As the lines between real and fake blur, the industry faces a fundamental question: what happens when the documents we have always relied on can no longer be trusted?

The Emerging Breakdown of Document Trust

AI now makes it possible to fabricate convincing corporate records, beneficial ownership structures, historic filings and identity documents, all with the appearance of legitimacy. What once required expertise and time is now achievable with readily available tools. The majority of companies remain genuine, but the small percentage of sophisticated falsifications represents a systemic vulnerability.

The implication is profound: Traditional document-driven verification no longer provides the assurance it once did. Email exchanges, PDFs and notarised copies aren’t inherently reliable when the underlying content can be artificially generated or manipulated at scale.

Why the Old Model No Longer Works

The challenge is not simply the documents themselves, but the process behind them. Most AML/KYC workflows remain dependent on information submitted by the investor, creating a single point of failure. Manual reviews are done; however, it is harder to distinguish between genuine documentation and high-quality AI-generated forgeries.

This makes a structural shift unavoidable. Verification must increasingly rely on independently sourced, authoritative data rather than investor-supplied documents. Corporate registries, supervisory bodies and tax authorities offer information tied to regulatory oversight and embedded governance, which provides more durable assurance than documents alone. While no single source is perfect, combining multiple trusted datasets makes falsification significantly harder to sustain.

AI as Part of the Solution

Although AI is a driver of the threat, it is also essential to the defence. Used responsibly, AI can compare information across jurisdictions, flag inconsistencies, detect anomalies in company structures and maintain continuously updated profiles of clients. This opens the door to perpetual compliance, a dynamic model that replaces the current cycle of onboarding followed by years-long gaps before the next review.

Corporate structures and ownership can change dramatically in months. AI-enabled monitoring of independently sourced data means AML/KYC no longer has to lag behind real-world developments.

The Case for Interoperability and Collective Defence

A further weakness in today’s environment is fragmentation. Administrators, transfer agents and asset managers each conduct their own AML/KYC checks, often without visibility into decisions made elsewhere. Fraudsters exploit these gaps.

The industry needs a more interconnected ecosystem, where systems are interoperable and trusted data can be exchanged securely, and through consent, remain GDPR compliant. This does not mean a single shared utility, but rather a collaborative architecture that allows risk signals and verified information to flow between platforms, reducing duplication and strengthening the collective defence against financial crime.

Learning From Other Sectors

Similar challenges have already been addressed in other industries, offering inspiration for financial services. In healthcare, AI models compare scans against thousands of other images to identify abnormalities. A technique that could be used to compare companies across peer groups to detect unusual patterns in structure or behaviour. In agriculture and food supply chains, tokenisation is used to trace products from origin to supermarket, creating tamper-resistant provenance records. The same principles could underpin future approaches to tracking corporate identity and document provenance in financial crime prevention, including their incorporation into blockchain-based systems.

These analogies highlight a broader truth: the technologies needed to rebuild trust already exist. The challenge lies in adapting them to an AML/KYC context.

What Firms Should Do Now

The evolving threat landscape requires boards and executive teams to take a more active stance. Protecting the firm from fraud, money laundering and regulatory exposure is not simply a matter of enhancing checklists. It demands a change in mindset and architecture.

Four priorities emerge clearly:

  1. Shift from document-driven to data-driven verification using independently sourced, authoritative information.
  2. Move toward perpetual compliance, replacing episodic reviews with continuous monitoring of client profiles.
  3. Digitise and simplify AML/KYC processes to reduce friction while strengthening defences.
  4. Collaborate across the ecosystem, developing a collective defence that prevents bad actors from exploiting gaps between firms.

The collapse of document trust is not an isolated threat; it is a systemic one. The firms that respond early with a modern data foundation, smarter technology and collaborative architectures will be best positioned to maintain trust in a world where fraud is increasingly automated.

Click here to listen to the full recording regarding this article.

Redesigning Onboarding in the Age of Financial Crime

In the latest episode of State of the Art, Reseo’s podcast on innovation, regulation and trust in investment management, host Pierre-Yves Rahari speaks with Heidi Gunkel, Managing Director and Head of Client Experience at RBC BlueBay Asset Management, about why onboarding has become one of the most critical and fragile moments in the investor relationship.

This article looks at how rising expectations are reshaping investor experience, why onboarding is now a competitive differentiator, and how firms can rethink their operating models in an era of global financial crime

Onboarding as the First Real Test

Servicing, onboarding and operations were brought together to support investors across Europe and APAC throughout the life of the relationship. The ambition is simple to describe, but harder to deliver the entire client journey from the first email to the last day.

Within that journey, onboarding stands out as the first real proof point. It is the moment when the manager stops pitching and starts asking questions; when documents are exchanged, risk appetites are probed, and working styles are exposed. Heidi calls it the “honeymoon phase” because both sides are getting to know each other and forming impressions that will last.

If the process feels smooth, transparent and respectful of the client’s time, it creates confidence. If it is slow, opaque or repetitive, that frustration lingers. Because investors compare experiences across providers, any perceived delay or additional request is quickly challenged: Why is this firm asking for more than others? In that sense, onboarding has become far more than a compliance requirement. It is a competitive arena in which managers are judged not only on performance, but on how easy they are to do business with.

Complexity at the Most Delicate Moment

The challenge is that this “honeymoon phase” now coincides with a period of unprecedented regulatory complexity. AML and KYC rules have tightened globally, with European frameworks layered on top of local interpretations, ESG-related disclosures and fund-specific requirements. The direction of travel is clear: More scrutiny, more documentation, more expectations on firms to know their clients and the sources of their capital.

Most institutional onboarding journeys span several jurisdictions. A London-based asset manager may be offering a Luxembourg or Irish UCITS to an investor in North America, Asia or continental Europe. Each of those locations brings its own rules, norms and supervisory expectations. It is common to have two or three regulatory regimes involved in a single relationship, just at the point when the parties are still learning to work together.

This is also where the ecosystem nature of modern fund structures becomes obvious. In a pooled fund, the asset manager is only one actor amongst many. Administrators, transfer agents and management companies all play their part in the onboarding process. The client receives a substantial information pack and then enters a back-and-forth with the administrator, while the manager tries to support the relationship. The starting point is clear, the end point, less so. An account may open in a few days, or take weeks or months, depending on the structure of the client and the assessment of beneficial ownership.

For investors, this can feel like a series of disconnected hurdles rather than a coherent journey. For managers, it is a situation in which they own the relationship but not the infrastructure, and that tension sits at the heart of many onboarding frustrations.

The Experience Gap: What Technology Promises and What It Delivers

Outside work, most investors are used to seamless digital experiences. They open bank accounts on their phones, sign documents electronically, track deliveries in real time and rarely must enter the same information twice. Against that backdrop, institutional fund onboarding can feel very frustrating.

Heidi’s vision of a better model is straightforward: A single digital front door through which the investor uploads documents, signs forms, monitors progress and later accesses reporting and servicing tools. Behind that front end, the administrator and other service providers can do their work, but the investor’s interaction remains simple and unified. In an ideal world, she suggests, the client would not need to know who the administrator is at all.

The reality in most organisations is patchier. Different parties use different systems. Workflows are not always connected end-to-end. Status updates can be hard to obtain and even harder to interpret. The result is that friction accumulates in precisely the place where clients expect clarity and ease.

Technology can address a large part of this, but only if firms are willing to make coordinated choices. Shared workflow tools that span asset managers and administrators, well-designed portals that present a single view to clients, and smarter use of data to avoid asking for information that is already publicly available can all reduce the burden. Heidi believes technology could realistically cover much of the heavy lifting, leaving people to focus on judgement, nuance and communication. But that requires agreement across the ecosystem, not just within a single firm.

Moments That Matter and Walkaway Moments

One of the walkaway moments is the AML/KYC phase during onboarding. If the investor experiences repeated, poorly explained requests for documentation or feels that the left hand and right hand of the organisation are not coordinated, the damage is difficult to repair. Another point is reporting accuracy later in the relationship: A single error might be forgiven, but repeated mistakes with the same client can be decisive.

The lesson is not that every element of the client journey can be perfect, but that some moments carry far greater weight than others. Firms that invest in understanding these pressure points and in redesigning processes, systems and responsibilities around them are more likely to build resilient, long-term relationships.

A Question for Boards: How Easy Are We to Deal With?

Looking three to five years ahead, Heidi expects to see more integrated portals, more consistent global processes and better use of workflow tools, particularly among larger managers with the scale to invest. Smaller firms may find it harder to keep up with both regulatory expectations and technology demands. Client experience cannot be left solely to the sales teams. AML/KYC analysts, operations, trade support, administrators and governance bodies all contribute to how a client experiences the firm.

For Boards and senior leaders, that means framing client experience as a strategic and measurable question, not just a soft concept. One question, in particular, should be asked regularly: How easy is it to do business with us? The answer should increasingly be based on data and structured feedback, rather than anecdotes.

In a world where financial crime is global, regulation is tightening and investors have more choice than ever, ease of doing business is no longer a nice-to-have. It is becoming a defining feature of trust.

Click here to listen to the full podcast based on this article.

 

Financial Crime Goes Global: How Europe Is Fighting Back

In the latest episode of “State of the Art,” Reseo’s podcast on innovation, regulation and trust in investment management, host Pierre-Yves Rahari sat down with Giles Swan, Public Policy and Regulatory Consultant, to explore how financial crime is evolving and how Europe is responding.

In this article, we look at how financial crime has become a truly global and technology-driven phenomenon, how the EU’s new Anti-Money Laundering Authority (AMLA) and AMLD6 directive aim to tackle it, and how technology is reshaping compliance and supervision across the investment industry.

The Globalisation of Financial Crime

Financial crime has long been part of the financial landscape, but its scale and sophistication have changed dramatically. According to the UN Office on Drugs and Crime, money laundering alone accounts for an estimated 2–5% of global GDP — between USD 2 trillion and 4.5 trillion annually.

“Those are huge numbers,” said Giles Swan. “They represent a significant issue not only for governments and regulators, but also commercially for firms that want to remain viable in a fast-evolving landscape.”

What’s new is the globalisation of financial crime. Enabled by technology, perpetrators now operate across jurisdictions, using digital networks to obscure ownership and move funds instantaneously. “We are not just dealing with local actors anymore,” Swan explained. “Technology has turned financial crime into an inherently cross-border challenge — involving both state and private actors with far greater sophistication than before.”

Europe’s Coordinated Response: AMLA and AMLD6

In response to this expanding threat, Europe is reshaping its anti-money-laundering (AML) and counter-terrorist-financing (CTF) framework. The creation of AMLA — the new European Anti-Money Laundering Authority, headquartered in Frankfurt — marks a major shift toward a coordinated, supranational model.

Historically, EU member states managed financial crime at the national level, resulting in divergent rules and supervision. AMLA’s mandate is to harmonise oversight and directly supervise certain high-risk, cross-border entities. “This is about joining up the dots,” said Swan. “The idea is to ensure that regulation keeps pace with the cross-border nature of financial crime, rather than being fragmented by national boundaries.”

Alongside AMLA, the sixth Anti-Money Laundering Directive (AMLD6) and accompanying AML Regulation aim to strengthen consistency across the EU. A key feature is the Ultimate Beneficial Ownership register, designed to improve transparency by requiring firms to identify and verify the individuals behind corporate structures — a move that will have deep implications for investment managers, fund administrators, and service providers.

“These rules demand greater use of technology,” Swan noted. “Manual processes that were once sufficient under earlier directives won’t be enough. Firms will need systems that can handle complex ownership structures efficiently.”

Collaboration, Technology, and Compliance in Practice

As regulations tighten, investment firms are re-evaluating their compliance frameworks. The focus is shifting from reactive reporting to proactive data analysis and technology-driven detection.

“The landscape is inherently technological now,” Swan said. “In the crypto-asset sector, for example, blockchain analytics tools like chain analysis are being used directly to track and prevent financial crime. That’s a model from which the traditional asset management industry can learn.”

He points to a convergence between RegTech (for firms) and SupTech (for regulators). Both sides are exploring how AI, distributed ledger technology, and real-time data can improve risk identification and reduce false positives. “There’s an exciting partnership potential here,” Swan added. “Regulators don’t need to reinvent the wheel — they can build on what the industry has already developed.” 

The Road Ahead: A Smarter Regulatory Future

As enforcement becomes more coordinated, firms can expect more cross-border actions and deeper scrutiny of control frameworks. Yet the shift also presents an opportunity: greater regulatory convergence across the EU could reduce friction for compliant firms and enhance trust with clients and counterparties.

Swan emphasised that boards have a central role to play. “Every board should ask two questions,” he advised. “First, how are our financial crime policies being implemented in practice? Second, what is our weakest link? That’s where the greatest exposure lies — whether in a management company, fund structure, or service provider.”

Ultimately, fighting financial crime requires a balance of vigilance, collaboration, and technological innovation. “The good news,” Swan concluded, “is that regulators and industry are finally moving in the same direction.”

Click here to listen to the full podcast based on this article.

New episode: Regulation Ramp-Up — The Coming AMLA Regulation and Its Impact on the EU and UK

Welcome back to a new season of Reseo’s State of Art podcast — where we speak with industry experts about the ideas and forces shaping the future of investment management.

In this episode, Pierre-Yves Rahari, Co-Founder and Director at Reseo, is joined by Giles Swan, a Public Policy and Regulatory Consultant.

Together, they discuss how the upcoming Anti-Money Laundering Authority (AMLA) regulation — set to take effect in July 2027 — will reshape the regulatory landscape, and what it means for firms, clients, and compliance practices. They also reflect on the evolving relationship between regulation, technology, and financial crime prevention, and how the industry can act now to prepare for what’s ahead.

  • Guest:Giles Swan — Public Policy Consultant, Swan FS
  • Host:Pierre-Yves Rahari— Co-Founder and Director, Reseo
  • Produced by: Melanie Lopes — Sales & Marketing Associate, Reseo

Thanks for listening to the Reseo State of the Art podcast – you can find us here and on Spotify.

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