This Week in Global Compliance — Supervisors Target Structural Gaps
This Week in Global Compliance — Supervisors Target Structural Gaps
November 14, 2025 — Week of 8–14 November
Executive Summary
Supervisors and policymakers spent this week tightening the “plumbing” of global AML and sanctions frameworks rather than announcing headline-grabbing mega-fines. In Europe, work accelerated on consolidating AML supervision and clarifying how the new authority will coordinate with national regulators. In North America, authorities focused on casinos, money services businesses and intermediaries that sit just outside the traditional banking perimeter. Across APAC, supervisors flagged weaknesses in beneficial ownership data and cross-border remittances, particularly where digital channels and alternative payment rails are involved. Crypto, once again, appeared as an enabling layer rather than the main story: mixers, OTC brokers and offshore exchanges continued to draw attention as infrastructure for laundering. For compliance leaders, the big picture is clear: regulators are now less tolerant of structural gaps in supervision, governance and data, and they expect firms to move from one-off remediation to systemic change.
Top Signals
- Europe advances consolidated AML supervision blueprint
A major European policy forum this week outlined how a single regional AML authority would share responsibilities with domestic supervisors, including joint inspections, data-sharing protocols and escalation pathways for “persistently non-compliant” institutions.
Why it matters:
Firms that previously played the arbitrage game between different national standards will find that strategy increasingly risky. Cross-border banks, payment providers and RegTech vendors will need to align to a single supervisory “language” for risk assessments, suspicious activity reporting and data quality.
- North American focus shifts to gambling, MSBs and non-bank intermediaries
Authorities in North America used a series of public statements, guidance notes and enforcement actions to highlight vulnerabilities in casinos, online gaming platforms and money services businesses. The common theme: cash-intensive sectors and loosely monitored intermediaries are still key nodes in organised crime and cartel financing.
Why it matters:
Banks that treat these sectors as “low touch” correspondent or acquiring relationships are underestimating their exposure. Relationship managers and onboarding teams should expect tougher questions from internal risk committees, and non-bank firms should anticipate more detailed requests for transaction data and customer risk models.
- Sanctions enforcement zeroes in on infrastructure, not just counterparties
Sanctions authorities continued a trend of targeting the infrastructure that enables evasion rather than only naming individual entities. Hosting providers, payment processors, freight/logistics companies and regional financial hubs all featured in this week’s updates as vectors for sanctions circumvention and trade-based money laundering.
Why it matters:
Compliance teams can no longer treat sanctions as a static name-and-number list problem. Understanding supply chains, data flows and service dependencies is becoming as important as screening client names. Procurement, tech and operations need to be embedded in sanctions risk assessments.
- Supervisors sharpen expectations on AI, data lineage and model governance
Multiple regulators reiterated that AI and machine-learning tools used in KYC, screening and monitoring must be explainable, auditable and backed by robust data-lineage documentation. Supervisors signalled that “black-box” models and poorly documented third-party tools will be challenged.
Why it matters:
For banks and fintechs, the question is shifting from “do you use AI?” to “can you show us how it works, what data it uses and how you monitor drift, bias and performance?”. Vendors that cannot provide clear documentation and test results will find themselves excluded from critical mandates.
Deep Dives
1. Supervision & Governance — Towards fewer blind spots
Regulators in Europe and North America made it clear this week that fragmented supervision has outlived its usefulness. Consolidation of AML oversight, clearer mandates for new regional authorities and more structured data-sharing are at the centre of reform. Rather than issuing long lists of new rules, supervisors are focusing on three pillars:
- Clarity of responsibilities: Who owns which risk, in which sector and in which jurisdiction.
- Quality of information: How suspicious activity reports, cross-border payment data and beneficial ownership records are collected, validated and shared.
- Follow-through: What happens when systemic weaknesses are identified, including timeframes for remediation and escalation routes to senior management and boards.
Practical impact:
- Banks must map their global entity structures against the emerging supervisory architecture and identify where responsibility for AML/CTF oversight genuinely sits.
- Fintechs and PSPs will need to move from “best effort” governance towards documented, board-approved frameworks, particularly for higher-risk corridors and products.
- Professional-services firms (audit, legal, corporate services) are likely to see a sharper line between advisory work and regulated AML obligations.
2. Sanctions & Geopolitics — Infrastructure in the crosshairs
Sanctions bodies continued to emphasise that non-financial infrastructure can be just as critical as banks in enabling illicit flows. This week’s actions and guidance focused on:
- Service providers that knowingly or recklessly support sanctioned parties, including hosts, telecoms and logistics firms.
- Complex webs of shell and front companies used to obscure the true ownership of trading houses, shipping companies and energy brokers.
- Financial intermediaries that provide “last-mile” access to the global financial system, such as small banks, payment aggregators and exchange houses.
Practical impact:
- Sanctions screening must evolve to include key infrastructure partners and third-party ecosystems, not only direct clients and counterparties.
- Trade-finance teams need richer data on supply chains and beneficial owners, including vessel ownership, routing and insurance arrangements.
- Firms should prepare for more joint actions and information-sharing demands across jurisdictions, with shorter timelines and less tolerance for incomplete responses.
3. Tech, Crypto & Typologies — Old risks on new rails
Several public communications this week highlighted the same pattern: traditional financial-crime schemes are being ported onto new rails — instant payments, alternative remittance channels, gaming platforms, decentralised finance and tokenised assets. Key typologies included:
- Layering via multiple low-value payments, exploiting instant settlement and weak controls in non-bank payment firms.
- Use of mixers, privacy tools and OTC brokers to break transaction chains before re-entry into the regulated system.
- Token-based casino and gaming chips, enabling rapid movement of value with limited KYC.
Practical impact:
- Transaction-monitoring models need to evolve beyond traditional card and wire patterns to cover instant payments, alternative rails and token movements.
- Crypto exposures must be mapped at the ecosystem level: who are the exchanges, brokers, custodians and service providers your clients rely on?
- Compliance, fraud and cyber teams should be working from a common playbook, particularly where ransomware, sanctions and fraud converge.
Data Points
- 60–70% of recent supervisory findings in some jurisdictions relate to governance, data quality and model risk, not to the absence of formal policies.
- Double-digit growth in reported attempts to exploit non-bank rails (PSPs, gaming, remittances) for layering, according to multiple FIU and regulator updates.
- Days instead of weeks — the typical timeframe now given by supervisors to respond to targeted data-requests or emerging-risk questionnaires.
Watchlist
- Final design of consolidated AML supervision in Europe — consultation outcomes in the coming weeks will define how cross-border firms are assessed and how data-sharing is enforced.
- Planned guidance on AI and algorithmic controls in monitoring, which could establish minimum expectations for explainability, documentation and testing.
- Further sanctions actions on infrastructure providers, especially in energy, logistics and telecoms, which may trigger rapid repricing of risk in trade corridors.
- Expanding reviews of non-bank sectors (asset managers, payment firms, corporate-service providers), signalling a more holistic supervisory approach.
Sources
This brief synthesises public communications from regulators, finance ministries, financial intelligence units, and supervisory bodies across Europe, North America and APAC, as well as selected enforcement actions, industry statements and sanctions updates published during the week of 8–14 November 2025.