Combatting financial crime with AI at the crossroads of the revised EU AML/CFT regime and the AI Act

The integration of artificial intelligence (AI) into the area of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) marks an essential shift in how financial institutions and regulators approach the fight against financial crime. In the EU, in 2024, two major regulatory projects reached key milestones: the revision of the AML/CFT framework and the adoption of the AI Act. Although these legislative efforts progressed in parallel, there appears to have been limited coordination between the drafters, resulting in considerable inconsistencies and areas of ambiguity. Even such seemingly basic – yet crucial – issues as the consistent application of the definition of an AI system, the determination of risks possibly entailed by such a system, or the terminology concerning human oversight give rise to concerns. The present article has two primary objectives: first, to provide an in-depth analysis of the interplay between the AI-relevant provisions of the revised AML/CFT framework and the AI Act, highlighting instances of conceptual confusion and practical challenges that those implementing AI in the AML/CFT area may have to face; and second, to identify and examine the areas where the problematic interplay between the two regimes may negatively affect the scope and availability of the protective human rights standards enshrined in the AI Act.

Authors

Publication Details

Journal
Research portal (Tilburg University)
Published
2026-01-13
DOI
https://doi.org/10.1177/203228442514086
Primary Topic
Crime, Illicit Activities, and Governance
Type
article
Field-Weighted Citation Impact
0.00
Controls
|||
ALL TIME
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
article

Combatting financial crime with AI at the crossroads of the revised EU AML/CFT regime and the AI Act

Magdalena; id_orcid 0000-0001-5734-3862 Brewczyńska
Research portal (Tilburg University)
Crime, Illicit Activities, and Governance
article

Combatting financial crime with AI at the crossroads of the revised EU AML/CFT regime and the AI Act

Magdalena; id_orcid 0000-0001-5734-3862 Brewczyńska
article en

Abstract

The integration of artificial intelligence (AI) into the area of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) marks an essential shift in how financial institutions and regulators approach the fight against financial crime. In the EU, in 2024, two major regulatory projects reached key milestones: the revision of the AML/CFT framework and the adoption of the AI Act. Although these legislative efforts progressed in parallel, there appears to have been limited coordination between the drafters, resulting in considerable inconsistencies and areas of ambiguity. Even such seemingly basic – yet crucial – issues as the consistent application of the definition of an AI system, the determination of risks possibly entailed by such a system, or the terminology concerning human oversight give rise to concerns. The present article has two primary objectives: first, to provide an in-depth analysis of the interplay between the AI-relevant provisions of the revised AML/CFT framework and the AI Act, highlighting instances of conceptual confusion and practical challenges that those implementing AI in the AML/CFT area may have to face; and second, to identify and examine the areas where the problematic interplay between the two regimes may negatively affect the scope and availability of the protective human rights standards enshrined in the AI Act.

Research portal (Tilburg University)
Peace, Justice and strong institutions
Openalex Percentile: Top 85%
Crime, Illicit Activities, and Governance
AI Navigator

Ask Laika to Summarize, Analyze, and Connect papers live on the map.

Summarize Papers & Methodologies

Extract key findings, datasets, and comparative methods across publications.

Benchmark Rankings & Visual Analytics

Rank top research institutions, authors, funders, topics, and journals by Field-Weighted Citation Impact (FWCI) and paper volume with instant charts.

Connect Distant Disciplines

Bridge topological clusters on the map to find hidden collaborative intersections.

Combatting financial crime with AI at the crossroads of the revised EU AML/CFT regime and the AI Act — Magdalena; id_orcid 0000-0001-5734-3862 Brewczyńska · Research portal (Tilburg University) (2026) | TGRS Research Map | TGRS