This thesis examines the effectiveness of the European Union’s framework for supervisory enforcement and institutional liability of credit institutions in the fields of anti-money laundering (AML) and EU sanctions compliance. The analysis focuses on the relationship between EU-level harmonization and national implementation, as well as on the role of supervisory authorities in ensuring the consistent enforcement of compliance obligations.
The study analyses the EU anti-money laundering and sanctions frameworks, the obligations imposed on credit institutions, and the supervisory architecture governing their enforcement. Particular attention is devoted to the interaction between AML and sanctions compliance, the challenges arising from fragmented supervisory practices across Member States, and the evolving concept of institutional liability. The thesis further examines recent regulatory developments, most notably the establishment of the Anti-Money Laundering Authority (AMLA), and assesses its potential contribution to greater consistency in supervision across the Union.
The findings demonstrate that the European Union has developed a comprehensive and increasingly harmonized regulatory framework aimed at preventing money laundering, terrorist financing, and the circumvention of restrictive measures. However, despite significant legislative progress, important differences in supervisory practices and enforcement approaches continue to affect the consistency and predictability of regulatory outcomes across Member States. The analysis further reveals a shift from a liability model focused primarily on individual compliance failures to a broader concept of institutional responsibility encompassing governance arrangements, risk-management systems, and internal controls.
The thesis concludes that legislative harmonization alone cannot ensure effective and uniform enforcement throughout the Union. While AMLA represents a significant step towards greater supervisory coordination and convergence, its long-term success will depend on effective cooperation between national authorities and the development of consistent supervisory standards across the EU.