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EEA payments enforcement is NCA-led and intensifying. European regulators issued over EUR 36m in AML fines against payments/e-money firms between March 2024 and March 2025 across ~30 enforcement actions, including licence revocations by the Bank of Lithuania (Foxpay) and Estonia's FIU (B2BX). The new EU Anti-Money Laundering Authority (AMLA) began operations in Frankfurt in July 2025, marking the start of direct EU-level supervision of high-risk entities. The European Commission also pursues infringement penalties before the CJEU for non-transposition.
On the supranational enforcement lever, the European Commission calculates CJEU infringement penalty payments on seriousness, duration and member-state ability to pay, with rulings binding on all member states; the calculation method was updated in March 2025 and March 2026. This non-transposition enforcement mechanism is directly relevant to the PSD3/PSR rollout, where member-state transposition timing will determine exposure.
Outlook
The trajectory is escalating. Licence revocations and rising AML fines against payments and e-money firms signal sustained supervisory pressure, while the updated CJEU infringement-penalty method gives the Commission a sharpened lever as the PSD3/PSR transposition phase approaches. Original financial-crime analysis remains routed to FIM.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (4)
- T3Finextra/Vixio; MyComplianceOffice
- T3Vixio AML Outlook
- T3ComplyAdvantage (AMLA reference)
- T1European Commission (Tier-1)