AMLA and OLAF sign a working arrangement: what it means for your reports

On 21 October 2026 the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) and the European Anti-Fraud Office (OLAF) signed a working arrangement on cooperation and information exchange. AMLA published a press release on 22 October, and OLAF issued the same text as a joint press release. It is the first of the four working arrangements that Article 94 of the AMLA Regulation (AMLAR) foresees with OLAF, Europol, Eurojust and the European Public Prosecutor's Office (EPPO) to be announced publicly. For obliged entities it changes nothing in the rulebook, but it says something about where the intelligence they produce will go and which typologies will attract attention. This article sets out what was signed, how it fits into the AMLAR, and what MLROs can usefully do with it.

What was signed

According to the press release, the arrangement does three things:

It sets a framework for cooperation and for the exchange of operational and strategic information between the two bodies, including criminal patterns, emerging trends, risk indicators and crime prevention methods.
It allows OLAF to contribute its anti-fraud expertise to joint analyses coordinated by AMLA, where the case is relevant to OLAF's mandate and subject to the consent of the Financial Intelligence Units (FIUs) taking part.
It frames this as support for joint operational analysis of money laundering connected with fraud involving EU funds.

AMLA Chair Bruna Szego summarised the rationale as follows: "Criminals do not respect institutional boundaries, and neither can our response." The text of the arrangement itself has not been published alongside the press release, so the practical modalities (liaison officers, secure channels, data-protection safeguards) are not known in detail. AMLA's Single Programming Document 2026-2028 had already announced that working arrangements with all four bodies would be concluded under Article 94 AMLAR, covering institutional, strategic and operational cooperation.

The legal basis in the AMLAR

Article 94 AMLAR is the provision on cooperation between AMLA and OLAF, Europol, Eurojust and the EPPO. It allows AMLA to conclude working arrangements with these bodies, within the limits of their respective mandates and of the OLAF Regulation (Regulation (EU, Euratom) No 883/2013). Two points matter for the reading of this arrangement:

OLAF is an administrative investigator. It investigates fraud, corruption and other illegal activity affecting the EU budget, and refers its findings to the EPPO or to national authorities. It does not prosecute and does not receive suspicious transaction reports directly.
The joint analyses that OLAF may now feed into are the FIU joint analyses of Article 40 AMLAR. These are analyses AMLA coordinates where a suspicious transaction or activity touches several Member States. Participation remains a decision of the FIUs concerned, and the arrangement expressly keeps that consent requirement. OLAF therefore does not get a seat at every joint analysis; it gets one where the FIUs agree and where EU funds are at stake.

This sits next to the ITS on the format for FIU reporting to the EPPO and the ITS on the format for AMLA reporting to the EPPO (both: Final text, awaiting publication). Those instruments cover the downstream channel from FIUs and AMLA to the prosecutor when there are reasonable grounds to suspect offences against the EU's financial interests. The OLAF arrangement covers the analytical stage before that, where fraud expertise can help an FIU recognise that a money-laundering pattern has an EU-budget predicate.

Why fraud against EU funds is a money-laundering question

Fraud affecting the EU's financial interests is a predicate offence for money laundering under the AMLD6 definition of criminal activity, and the proceeds of grant, subsidy, procurement and customs fraud have to be placed and layered like any other criminal proceeds. The Recovery and Resilience Facility, cohesion funds, agricultural subsidies and research grants have all increased the volume of EU money flowing through national administrations and private beneficiaries in recent years. Typical laundering patterns that pass through obliged entities include:

Companies set up shortly before a tender or grant application, with opaque ownership and no operating history, receiving public funds and transferring them onwards within days.
Consultancy and subcontracting invoices between related parties that bring grant money back to the people who control the beneficiary.
Cross-border VAT carousel structures (large-scale VAT fraud is within the EPPO's remit above the EUR 10 million threshold of the PIF Directive) using payment accounts at several institutions.
Real-estate purchases and professional services funded by subsidies that were obtained on false declarations.

None of these patterns is new. What the arrangement changes is that OLAF's casework on the fraud side can now be matched, in a joint analysis, with the FIU intelligence that obliged entities generate. In practice this raises the probability that a report on a grant-funded company with unusual outflows is followed up across borders rather than closed locally.

What it means for obliged entities

There is no new obligation here. The reporting standard stays Article 69 AMLR: report to the FIU where you know, suspect or have reasonable grounds to suspect that funds are the proceeds of criminal activity, and respond to FIU requests for information within the deadlines set by the FIU. Three consequences are nevertheless worth noting.

Requests for information may increase in EU-funds cases. Where a joint analysis with OLAF input identifies accounts at your institution, the request will come from your national FIU, not from OLAF or AMLA. Article 69(1) AMLR requires obliged entities to provide all necessary information to the FIU on request, in principle within five working days. Your retrieval capability for transaction records and customer files should be able to meet that, and the draft ITS on the format for reporting suspicions and providing transaction records (Consultation closed, being finalised) will standardise the format of those records for credit and financial institutions.

Public-funding exposure belongs in the business-wide risk assessment. If your customer base includes recipients of EU or national subsidies, public contractors, or intermediaries in agricultural or structural-fund schemes, that is a risk factor to document. The draft Guidelines on the business-wide risk assessment (Consultation closed, being finalised) ask for a structured inventory of customer, product, geographic and delivery-channel risks; public-funding dependency can be captured under customer and product risk. The draft Guidelines on ongoing monitoring and transaction monitoring (Consultation closed, being finalised) expect scenarios to reflect the risks identified in that assessment, so a grant-fraud typology should have a corresponding detection logic if the exposure is material.

Expect typology feedback to flow back. The arrangement explicitly covers the exchange of risk indicators and crime prevention methods. AMLA's Guidelines on indicators of suspicious activity or behaviour (Announced, no draft yet; statutory deadline 10 July 2027) are the natural vehicle for turning OLAF's fraud indicators into something obliged entities can use in screening and monitoring. Until that guideline exists, national FIU typology reports and OLAF's annual report remain the public sources.

The wider cooperation picture

The OLAF arrangement is one piece of a cooperation architecture that AMLA is assembling in parallel with its standards work:

Working arrangements with Europol, Eurojust and the EPPO under the same Article 94 AMLAR are planned; Europol's own programming document for 2026 lists an arrangement with AMLA as an objective. None has been announced publicly yet.
The RTS on cross-border information exchange between FIUs (In consultation; consultation period ran from 6 July to 6 October 2026; final draft scheduled for Q4 2026) will determine when a report concerns another Member State and how it is passed on within FIU.net.
The ITS on the format for the exchange of information between FIUs (Final text, awaiting publication) provides the templates that make such exchanges, and the joint analyses built on them, machine-readable from 2028.
FIU.net itself transfers to AMLA by 2027.

Taken together, a report filed with one national FIU in 2027 will be far more likely than today to be matched with intelligence from other FIUs, from OLAF and, through the EPPO channel, from prosecutors. The quality of the narrative in that report (who the parties are, which public funds are involved, why the flow is inconsistent with the customer profile) determines whether the match happens.

What to do now

Read the press release and note that no text of the arrangement has been published; do not assume details beyond what it states.
Check whether your customer segmentation can identify recipients of EU and national public funding, public contractors and subsidy intermediaries. If it cannot, add the data point to the customer file during the next review cycle.
Record public-funding exposure in the business-wide risk assessment and decide whether it warrants a dedicated monitoring scenario (rapid onward transfer of incoming public payments, related-party invoicing, newly incorporated beneficiaries).
Test the time needed to assemble full transaction records and customer files on request, against a five-working-day target under Article 69(1) AMLR.
When a suspicion involves EU funds, say so in the report: name the scheme or contract if known. It helps the FIU decide on cross-border dissemination and on bringing the case into a joint analysis.
Brief the compliance manager and the board in the next AML/CFT update: cooperation between AMLA and the EU investigative bodies is a factor in supervisory expectations for 2027, even though it creates no new obligation.

The AMLR Monitor dashboard tracks the FIU and EPPO instruments mentioned in this article, the RTS on cross-border information exchange between FIUs and the guidelines on indicators of suspicion, with their current status.