Such risks—including the misuse of legal entities, third-party payments, and innovative compliance technologies—may impact solicitor firms and require enhanced vigilance in client and transaction due diligence.

EBA Opinion on ML/TF risks affecting the financial sector

The European Banking Authority (EBA) published its 2025 Opinion on money laundering and terrorist financing (ML/TF) risks affecting the EU’s financial sector, noting that 2025 marks a significant change in the ML/TF risk landscape. In a context of important geopolitical developments, legislative reforms and digitalisation, solicitors might be interested to learn that new ML/TF vulnerabilities are emerging. For example, the EBA stresses that a careless use of innovative compliance products can lead to money laundering and terrorism financing risks. This goes in parallel with risks escalating as automation and AI fuel increasingly sophisticated schemes.

• View the 2025 EBA report

FIU Netherlands - Annual review 2024: Companies abused as fronts

In its annual review, the Netherlands Financial Intelligence Unit (FIU Netherlands) shares the most important figures, trends and developments from 2024 impacting the financial sector. One of its worrying insights concerns extensive use by criminals of shell companies and straw owners to abuse the financial system. The analysis, based on reports of unusual transactions from reporting entities (including 24 from lawyers in 2024), reveals large-scale and organised abuse of legal entities. Seemingly legal business structures hide complex money laundering practices, tax fraud and even terrorist financing. Among others, the annual review discusses risks relating to third-party payments (a supplier delivering goods or services to a customer, while a third party makes the payment) and real estate.

• View the 2024 FIU review 

AML resources for solicitors

For more information and support on AML compliance including a dedicated email helpline for solicitors, visit the AML section of the website.