EMEA AML Survey 2026 - the Belgian perspective

Anti-money laundering (AML) efforts in Belgium face increasing complexity, driven by evolving financial crime risks, growing regulatory demands, and the urgent need for digital transformation. Institutions contend with rising compliance costs, operational bottlenecks in key areas such as Customer Due Diligence (CDD), and persistent talent shortages, all amid a rapidly shifting regulatory landscape.

Within the EU, the new AML Package marks the most significant regulatory overhaul to date, introducing a single rulebook, an EU-level supervisory authority, and far-reaching requirements. While Belgian firms demonstrate greater preparedness compared to their  peers, with fewer expecting to miss the 2027 compliance deadline, they still face significant operational, technological, and organisational challenges in implementation.

Despite substantial regulatory ambition, confidence in critical AML controls such as transaction monitoring remains low, and adoption of advanced technologies including AI is at an early stage. Data quality issues and limited cloud maturity further constrain progress, underscoring the need for strategic investments and operational adjustments.

As Belgium’s AML landscape evolves, firms must navigate these challenges while balancing cost pressures and talent risks, placing technology and innovation at the heart of their compliance strategies.

Discover what sets Belgian financial institutions apart in the evolving anti-money laundering (AML) landscape. Building on insights from 531 institutions across EMEA region, including banks, asset and wealth managers, electronic payments firms, crypto-asset service providers, and virtual asset firms. This edition broadens its scope with the inclusion of insurance companies for the first time, providing new insights into a sector facing some of the steepest compliance pressures.

We reviewed the responses of 19 Belgian financial institutions as part of the wider PwC EMEA AML Survey and found some clear differences and interesting insights about how Belgian firms are handling the changing AML environment.

AML compliance costs are on the rise globally, and Belgian financial institutions are no exception. 58% of institutions across EMEA expect these costs to increase by over 10% in the coming years, with up to 40% of EU respondents attributing these increases directly to the new EU AML Package. This regulatory overhaul is the most significant in over a decade, bringing major changes but also operational challenges.

In Belgium, as in the wider EU, preparedness remains uneven. Only a quarter of institutions have completed a detailed analysis or impact assessment of the new rules, with half of Belgian institutions expecting to be fully compliant by the July 2027 deadline—significantly more than the European average in the survey. 

Early reporting exercises by the newly established Anti-Money Laundering Authority (AMLA) have already exposed significant data and process gaps among financial institutions.

Outside the EU, regulatory fragmentation grows, widening the gap between regions and increasing complexity—something Belgian firms must navigate carefully as they operate across multiple jurisdictions. This evolving landscape highlights the importance of consistent and coordinated compliance approaches to remain competitive. 

Have you already done a detailed analysis of the practical implications of the new EU AML Package? (by type of respondent) (EU respondents)

^{Source: PwC Global AWM & ESG Research Centre
Note: Question asked to respondents from the EU and subject to EU Directives and Regulations. The percentages may not add up to 100% due to rounding.} 

Customer due diligence (CDD) remains the most significant operational challenge for Belgian financial institutions, reflecting broader EU trends. Institutions prioritise investments heavily in CDD-related activities, especially onboarding and periodical reviews, alongside key areas such as transaction monitoring and risk assessment. These priorities reflect a concerted effort to address the complex demands posed by the new EU AML Package over the next 24 months.

At the same time, institutions identify the same core Anti-Money Laundering /Counter Terrorism Financing controls, CDD onboarding, periodical review, risk assessment, and transaction monitoring, as those most impacted by the new regulations. Screening, reporting, and ‘know your assets’ processes are also highlighted as areas undergoing substantial change. The overlap between investment focus and impact expectations underscores the operational intensity and resource demands these areas will incur. 

This reflects widespread concerns among institutions, with over half ranking the draft Regulatory Technical Standards' rules-based approach over a risk-based one as their top issue, and more than a third citing the excessive volume of data collection as their primary concern. These critical challenges contribute to an uneven state of preparedness, as some institutions have yet to fully analyse or assess the impact on their controls, signalling ongoing uncertainty ahead of the July 2027 compliance deadline. Notably, a significant portion of institutions have yet to fully analyse or assess the implications of the new EU AML Package for their controls, reflecting ongoing uncertainty as the July 2027 compliance deadline approaches.

Around 60% of Belgian institutions plan to reallocate internal resources for EU AML/CFT implementation, with some increasing staff mainly in compliance or across multiple functions. Many are also considering outsourcing key activities such as transaction monitoring, screening, Know Your Customer onboarding, periodic reviews, and remediation. This reflects a balanced approach to managing talent shortages and operational demands. In fact, more than half of institutions plan to invest in technology to reduce reliance on large AML staff numbers, while a smaller share report struggling with shortages of qualified personnel. A notable portion emphasises the need to enhance salary and benefits to retain talent, with some also citing market and industry attractiveness as key retention factors. Aggravating this trend, a quarter of institutions believe there is a risk of staff leaving to join the newly formed AMLA. 

Confidence in the effectiveness of transaction monitoring systems is low among Belgian institutions, with only about 20% fully confident in their current setups being fit for purpose according to the EU AML Package. The vast majority (over 70%) acknowledge shortcomings, but plan to fine-tune their systems to meet the requirements, indicating widespread recognition of the need for improvement. This is significantly higher than the European average in the survey. Reflecting this, nearly 85% of institutions are actively planning reviews of their transaction monitoring or screening processes, with most initiatives driven at the group level and a smaller portion managed locally. Only a few firms are awaiting further group instructions before proceeding with updates.

A significant number of institutions still lack advanced tools for verifying document authenticity; only a quarter have implemented AI-driven solutions. Many continue to rely on traditional methods, while some are actively scouting for better technologies to enhance their verification processes. Most institutions anticipate a significant increase in operational KYC efforts due to the new review periods, with the majority expecting workload rises between 10% and 20%. A smaller but notable number foresee an even stronger impact, anticipating increases exceeding 20%, while only a few expect minimal or weak effects. 

Facing regulatory pressures and talent shortages, Belgian institutions are increasingly outsourcing key AML activities and investing in technology to improve efficiency. These changes reflect a strategic shift to adapt operational models and ensure compliance ahead of the 2027 deadline amid ongoing challenges.

Are you confident that your transactions monitoring is fit for purpose? (all respondents)

^{Source: PwC Global AWM & ESG Research Centre
Note: Question asked to all respondents. The percentages may not add up to 100% due to rounding.}

In Belgium, almost 80% of institutions prioritise new technology investments in customer due diligence, alongside transaction monitoring, risk scoring, screening, and remediation. This reflects a broad effort to modernise AML controls and meet evolving EU regulatory requirements.

Belgian institutions show growing interest in prioritising AI technologies, such as machine learning and agentic AI, for AML processes. However, readiness to implement the required human oversight under the new EU AML Package varies across firms.

Most Belgian institutions recognise the need to improve their data infrastructure to meet new EU AML package requirements, with the majority planning significant or complete overhauls of their AML reporting systems. This highlights widespread acknowledgment that enhancing data quality is essential for effective compliance and for leveraging AI-driven AML solutions.

More than one-third of institutions anticipate major or complete overhauls to their data infrastructure, indicating a move toward large-scale digital transformation instead of incremental adjustments. 

Cloud technology adoption remains limited among Belgian institutions, with only a few having invested in cloud solutions for their AML/CTF tools. Without substantial advancements in data infrastructure and cloud maturity, Belgian organisations risk falling short of their technological and regulatory AML objectives.

Are you considering implementing AI in your AML processes/workflows? (all respondents)

^{Source: PwC Global AWM & ESG Research Centre
Note: Question asked to all respondents. The percentages may not add up to 100% due to rounding.}

Belgian financial institutions face ongoing challenges preparing for the EU AML Package, including rising costs, operational pressures in customer due diligence, and talent shortages. While many are still assessing regulatory impacts, nearly 80% prioritise technology investments in customer due diligence and transaction monitoring, with the small but growing adoption of AI tools—though readiness for required human oversight varies.

As we have seen, there are four challenges that institutions need to overcome to move forward. Firstly, data quality and infrastructure remain major obstacles, prompting significant planned system upgrades. Secondly, talent retention issues persist, partly due to competition from AMLA, leading firms to balance internal resource shifts with outsourcing key AML functions. Thirdly, confidence in transaction monitoring is low, driving widespread review plans.

These challenges have resulted in Belgian institutions pursuing a mix of innovation and operational adaptation to strengthen compliance and prepare for the 2027 deadline.