Immediate Outcome 6 (IO.6) asks a hard question: is financial intelligence actually used to detect, investigate and prosecute ML/TF, and to trace and confiscate proceeds? In the Egmont Europe II horizontal analysis, IO.6 is where most jurisdictions struggle. Out of 23 FIUs in the region, only 6 (26%) receive a High or Substantial rating, while 15 (65%) are rated Moderate and 2 (9%) Low. The report’s conclusion is blunt: in most systems, financial intelligence is used only to some extent or to a negligible extent, and major or fundamental improvements are still required to reach genuine effectiveness. For FIUs, supervisors and policymakers, IO.6 has become a central indicator of whether their investment in reporting regimes, analytics and cooperation is actually paying off.
Under the FATF methodology, IO.6 focuses on the collection, access, analysis and use of financial intelligence across FIUs and competent authorities, and on whether that intelligence supports concrete ML/TF outcomes.
Assessors look for evidence that:
Crucially, IO.6 is not about whether a country has an FIU and STR law on paper. It is about whether financial intelligence is central to the AML/CFT response and visible in case outcomes.
The horizontal analysis shows that Europe II’s IO.6 problems are systemic, not incidental. Typical weaknesses include poor STR quality, limited FIU resourcing and analytical capacity, under-use of FIU outputs by LEAs, weak strategic analysis and delays in cooperation.
Low-effectiveness systems are characterised by poor-quality STRs. Reporting entities (especially DNFBPs) submit large volumes of reports “to be safe” rather than because they actually suspect ML/TF.
This produces three problems:
The analysis highlights STR quality as a core weakness in 53% of Moderate-effectiveness jurisdictions under IO.6.
Many FIUs operate with insufficient human and technological resources, limited access to key databases and fragile analytical environments.
This constrains:
Partially compliant R.29 jurisdictions are specifically flagged for insufficient human and technological resources and weak analytical capacity, which undermine IO.6 outcomes.
Egmont identifies LEA use of financial intelligence as a decisive horizontal element for IO.6. Where IO.6 is weak, FIU disseminations are often underused: few lead to the initiation of investigations, or they are not integrated into evidence packages and asset-tracing efforts.
Key findings:
In practical terms, this means that even FIUs that produce reasonable products may still see poor IO.6 ratings if LEAs and prosecutors do not systematically act on them.
Strategic analysis is intended to translate FIU data into typologies, red flags and thematic studies that inform supervisors, LEAs and reporting entities.
However, in many Moderate or Low jurisdictions:
The report notes strategic analysis as a weakness in 53% of Moderate-effectiveness and 50% of Low-effectiveness jurisdictions, making it another key drag on IO.6 ratings.
By contrast, the Egmont analysis identifies a consistent pattern in Substantial and High-effectiveness jurisdictions.
Core features include:
Notably, the analysis shows that in Substantial-effectiveness systems under IO.6, the most common strengths are:
The Egmont report consolidates IO.6 recommendations into a clear agenda for jurisdictions aiming to move from Moderate to Substantial or High effectiveness.
Key priorities:
These reforms are deliberately operational: they go beyond amending laws to changing how financial intelligence is generated, analysed and used day-to-day.
Throughout the analysis, Egmont associates higher IO.6 performance with stronger IT systems, broad data access and structured workflows.
Modern FIU platforms (such as FIU360-type architectures) can support IO.6 improvements by:
Technology alone will not fix IO.6, but without it, many of the recommended reforms (especially around analytics, coordination and evidence-gathering) become significantly harder to implement.
Egmont’s Europe II horizontal analysis shows that most jurisdictions only partially achieve IO.6. Poor-quality STRs, limited FIU resources, weak strategic analysis and under-use of FIU products by law enforcement keep ratings at “Moderate”. High-performing systems combine strong IT, national coordination, robust analysis and systematic LEA use of financial intelligence. The report offers a clear operational reform agenda for jurisdictions aiming to reach Substantial or High effectiveness.