In a bold intervention during the recent AMLA implementation roundtable hosted at the European Parliament, Oonagh van den Berg, Founder of RAW Compliance AI and Executive Director of Growth & Advisory at AML Watcher, called for a radical rethinking of how financial crime regulation is designed and applied across the EU.
Addressing an audience that included European Commission officials, the EBA, and financial crime leaders, Oonagh mentioned that the promise of a risk-based approach is being smothered under a growing mountain of prescriptive rule-making and legalism.
“Until we start stripping back overly legalistic frameworks and empowering institutions to apply true risk intelligence, we’ll never escape the trap of box-ticking compliance,” said van den Berg. “Risk-based approaches aren’t magic words. It’s a mindset shift, and that starts with removing the fear of regulatory retaliation when firms dare to apply judgment over form.”
The roundtable, focused on the upcoming operationalisation of the European Anti-Money Laundering Authority (AMLA), echoed a familiar buzzword throughout: risk-based approach. Yet Oonagh was quick to highlight the disconnect between rhetoric and reality.
“What we have across much of the EU is regulatory-based compliance dressed up as risk-based strategy. A checklist is still a checklist, no matter how many buzzwords you throw at it.”
Among the key issues discussed were:
- Overregulation and its unintended consequences: “It leads to poor customer experience, financial exclusion, and ironically, more risk,” Oonagh noted.
- Crypto compliance challenges: Governance remains patchy and jurisdiction shopping continues, fueled by regulatory uncertainty.
- The technology gap: Financial crime tech innovation is struggling to keep pace with the speed and complexity of new scams.
- Fintech under pressure: Labeled high-risk not by design, but because compliance maturity often lags behind product innovation.
Despite these concerns, Oonagh voiced optimism, pointing to successful public-private initiatives like EFIPPP as models of constructive, collaborative oversight.
“We don’t need more regulation. We need better regulation. And AMLA has a real chance to lead that change, if we let it.”
Oonagh van den Berg concluded with a challenge to both regulators and institutions: foster a culture where risk intelligence and professional judgment are encouraged, not penalized. In an era where threats are dynamic and technology is advancing at breakneck speed, true risk-based intelligence demands more than compliance checklists. It requires agility, trust, and the ability to make informed decisions in real-time backed by data, not driven by fear. As the EU charts the future of AMLA, the path forward must be one where innovation and integrity go hand in hand.