Welcome to our latest podcast episode, where we challenge orthodoxies and explore what’s next in risk and regulation.
This week’s podcast episode confronts a critical issue at the intersection of politics, compliance, and regulatory reform: the European Banking Authority’s consultation paper on the new AMLA mandates. Framed as a much-needed boost to the EU’s anti-money laundering capabilities, the consultation sets ambitious goals — harmonization, transparency, and stronger oversight.
But here’s the hard truth: the path it lays out may unintentionally undermine those very objectives.
In this episode, we unpack the potential pitfalls buried in the proposed rules:
Static risk models that ignore real-world complexity
Punitive frameworks that burden compliance professionals instead of empowering them
A focus on scoring and disclosure that eclipses real risk reduction
We also introduce a solution that’s gaining traction in forward-looking regulatory circles: risk accounting — a method that moves risk assessment from theoretical checklists to dynamic, quantifiable metrics at the transaction level. More than a tool, it offers a shift in mindset: from retrospective blame to proactive insight.
🏰 What’s with the fortress?
As we discuss on the show, the current proposals are like building a castle wall in pieces, each tailored to a different threat — fire, battering rams, climbing. But no matter how strong each piece is, the wall is only as good as its weakest, unintegrated point. Worse yet, the inspectors are focused on blueprints rather than intrusions.
We need a new kind of architecture. And risk accounting might just be the blueprint.
🎧 In This Episode, You'll Learn:
Why the EBA’s well-intentioned regulation could overload compliance functions
How static risk categories and fixed thresholds fall short in dynamic AML/CTF contexts
What risk accounting offers as a flexible, auditable, and data-driven alternative
How a “carrot vs. stick” regulatory model could foster real accountability — without scapegoating professionals
🔗 Listen now and decide for yourself:
Is this consultation a turning point for compliance, or a symptom of a system that’s still stuck in the past?
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