The Egmont Group has released a new study, “Enhancing the effectiveness of the AML/CFT mechanism through a horizontal analysis of Mutual Evaluation Reports”. The report looks across 23 jurisdictions in the Europe II Regional Group (largely MONEYVAL countries), focusing on FATF Immediate Outcomes 2 and 6 and Recommendations 29 and 40. Rather than ranking countries, the paper extracts recurring strengths, weaknesses and recommended actions around: • IO.2 – International cooperation • IO.6 – Use of financial intelligence • R.29 – Financial Intelligence Units • R.40 – International cooperation The message is blunt: technical compliance is no longer the benchmark. What matters is whether FIUs and competent authorities use financial intelligence in real investigations, asset recovery and prosecutions—and can prove it. For FIUs, supervisors and policymakers, this report is effectively a “how to pass the 6th-round effectiveness test” manual.
The study reviews FATF and MONEYVAL Mutual Evaluation Reports for 23 Europe II jurisdictions, applying a consistent lens to the parts that most directly concern FIUs and international information exchange.
Key features of the methodology:
The result is a set of horizontal findings that explain why some FIUs and AML/CFT systems score better than others, and what can realistically be fixed between evaluations.
The report confirms what many FIU heads already suspect: weaknesses are rarely unique to one country. They are systemic, and they repeat across the region.
Four problem areas stand out.
Across many MERs, evaluators criticise:
In practice, this means FIUs spend scarce capacity cleaning data or filtering low-value defensive reporting instead of generating high-impact intelligence. The Egmont analysis notes that STR quality and timeliness are repeatedly linked to weaker effectiveness ratings, even when a legal reporting framework is in place.
Moderate-performing jurisdictions typically show:
By contrast, higher-rated FIUs usually have strong IT platforms, broad data access and structured analytical functions—allowing them to produce timely, targeted intelligence products.
One of the clearest messages from the report is that FIU output is often under-used by law enforcement. In lower-rated jurisdictions, MERs repeatedly note that disseminations are not systematically feeding into investigations, asset tracing or case strategy.
Commentary around the report makes the point even more directly: effectiveness is judged “far less on whether an FIU produces intelligence—and far more on whether law enforcement and prosecutors systematically use it.”
For IO.2 and R.40, the horizontal analysis finds familiar shortcomings:
These factors combine to lower IO.2 scores even where cooperation frameworks exist on paper.
The report then identifies a contrasting set of traits in jurisdictions rated Substantial or High on IO.6 and IO.2. These are not abstract “good practices”; they are recurring features in MERs with better effectiveness ratings.
Three patterns are particularly important.
In stronger systems:
This is the difference between an FIU as a reporting mailbox and an FIU as a core operational partner.
Higher-rated jurisdictions tend to show:
These capabilities are exactly what effectiveness-focused assessors look for when they ask, “Is this FIU adding operational value?”
In better-performing jurisdictions, MERs frequently highlight:
In other words, international cooperation is treated as a core FIU function, not a side activity.
The Egmont horizontal analysis is more than a descriptive report. It functions as a practical agenda for anyone responsible for FIU performance or AML/CFT system design.
Three strategic shifts stand out.
For IO.6, the critical exam question has changed. Assessors now want evidence that:
That means FIUs should be ready to document the full chain:
dissemination → LEA action → investigative decisions → restraint / confiscation → prosecutions and other outcomes.
Without this, even technically strong FIUs risk moderate effectiveness ratings.
Supervisors and FIUs need to re-frame STR obligations as intelligence pipelines, not pure compliance chores. That includes:
The Egmont report clearly links STR quality and FIU analytical capacity to overall effectiveness ratings across Europe II.
R.40 and IO.2 effectiveness is now judged on speed, proactivity and practicality:
For many jurisdictions, this will require process redesign, capacity building and updated SOPs, not just new MoUs.
Based on the Egmont findings, an FIU director or national coordinator could realistically ask:
Treating these questions as a standing management agenda—rather than a one-off evaluation exercise—is likely to have the biggest long-term impact on IO.2, IO.6, R.29 and R.40.
One thread running through the report is the role of modern IT systems and data architecture. Higher-performing jurisdictions typically have:
For FIUs working with platforms like FIU360, the Egmont study effectively validates this direction of travel:
Technology alone is not enough—but without the right architecture, many of the recommended reforms are difficult to sustain or demonstrate.
One thread running through the report is the role of modern IT systems and data architecture. Higher-performing jurisdictions typically have:
For FIUs working with platforms like FIU360, the Egmont study effectively validates this direction of travel:
Technology alone is not enough—but without the right architecture, many of the recommended reforms are difficult to sustain or demonstrate.
Egmont’s new horizontal analysis of FATF and MONEYVAL Mutual Evaluation Reports across 23 Europe II jurisdictions shows that AML/CFT effectiveness hinges on four factors: STR quality, FIU capacity, operational use of financial intelligence, and timely international cooperation. High-performing jurisdictions systematically embed FIU outputs into investigations and asset recovery, supported by strong IT systems and proactive cross-border exchange. For FIUs and policymakers, the report is a practical roadmap for improving IO.2, IO.6, R.29 and R.40 ratings.