Belgium has made significant progress in strengthening its anti-money laundering and counter-terrorist financing (AML/CFT) framework. However, the Financial Action Task Force (FATF)'s 2025 mutual evaluation of Belgium, published on 16 December 2025, highlights a persistent gap between the country's regulatory framework and its effectiveness in practice. Although many of the necessary laws and supervisory mechanisms are in place, weaknesses remain in investigations, supervision, financial intelligence and the reliability of certain key data.
For financial institutions and other obliged entities, the report provides an important indication of the areas requiring attention. It highlights the need not only to comply with existing AML/CFT requirements, but also to demonstrate that controls effectively identify, assess and mitigate risks.
How effective is Belgium's AML/CFT framework today?
FATF recognises that Belgium has strengthened its AML/CFT framework through reforms introduced since the previous evaluation. The country's technical compliance with FATF Recommendations is largely aligned, reflecting the existence of a broad legal and institutional structure to combat money laundering and terrorist financing.
Nevertheless, the report identifies significant shortcomings in the effectiveness of implementation. In particular, limited resources available to law enforcement and judicial authorities continue to affect the investigation and prosecution of financial crime. These constraints can hinder the conversion of financial intelligence into investigations, prosecutions and confiscations.
Belgium has therefore been placed under enhanced follow-up, meaning that it must report back to FATF on progress in addressing the shortcomings identified in the evaluation. According to FATF's Belgium country page, the country has a roadmap of key recommended actions to be completed within three years: giving law enforcement and judicial authorities the resources and technological tools needed to investigate and prosecute financial crime, adopting a strategic approach to its main money laundering and terrorist financing risks, and targeting transnational criminal networks. That three-year horizon is the reference point against which Belgian authorities, supervisors and obliged entities can time their own remediation work.
Technically, Belgium remains largely aligned with the FATF Recommendations: 13 are rated compliant, 20 largely compliant, 6 partially compliant and 1 non-compliant. The single non-compliant rating concerns new technologies, and Recommendation 15 in particular, which covers virtual assets and the providers that service them. The measures rated below fully compliant cluster around beneficial ownership transparency and national cooperation. A consolidated view of Belgium's ratings is available on the FATF's country page for Belgium.
The central challenge is no longer simply to establish an appropriate regulatory framework, but to demonstrate that it produces tangible results.
What are the main money laundering and terrorist financing risks facing Belgium?
The evaluation identifies several persistent money laundering threats, including drug trafficking, cash-based criminal activity, social and tax fraud, other forms of fraud and organised crime. The assessment also emphasises how closely these activities are interconnected, including the links between money laundering and the financing of terrorism.
Criminal proceeds may be moved through cash transactions, concealed through legal entities or combined with revenues from apparently legitimate economic activities. Professional money launderers can further facilitate these schemes by helping criminal networks obscure the origin and ownership of their funds.
Virtual assets and the services associated with them also present evolving risks. Their cross-border nature and the speed with which transactions can take place create challenges for identifying suspicious activity and establishing the origin and destination of funds.
At the time of its on-site visit in January and February 2025, FATF found that no authority had been designated to licence and supervise virtual asset service providers, leaving a high-risk sector without the oversight that FATF's standards require. That finding reflects the position during the assessment period. The framework has changed since.
The Markets in Crypto-Assets Regulation (MiCA) has applied to crypto-asset service providers since 30 December 2024, and the Belgian law of 11 December 2025 implementing MiCA and the Transfer of Funds Regulation entered into force on 3 January 2026, with supervision divided between the FSMA, responsible for crypto-asset service providers, public offers and market abuse, the National Bank of Belgium for the issuance of asset-referenced and e-money tokens, and the FPS Economy for certain aspects of electronic money tokens. Institutions active in this area should assess their arrangements against the current framework rather than the position recorded in the report.
The report also identifies two less visible channels. Hawala and other informal value transfer systems are areas in which the detection of illicit activity remains limited, in part because the flows involved do not always pass through supervised institutions. Among non-financial sectors, diamond dealers are singled out as a high-risk activity for which supervisory resources, and therefore inspection coverage, remain insufficient. Obliged entities with counterparties in either area have a direct reason to look more closely at those business relationships and at the payments associated with them.
Regarding terrorist financing, FATF draws attention to risks involving individuals linked to terrorism, including foreign terrorist fighters and radicalised individuals. Financing may involve relatively small amounts, micro-financing or funds originating from legitimate sources. This reinforces the importance of controls capable of detecting patterns of suspicious activity rather than relying exclusively on transaction size or the apparent legitimacy of a customer's income.
For additional context, the Belgian Financial Intelligence Processing Unit, CTIF-CFI, publishes information on money laundering and terrorist financing typologies, risk indicators and reporting. These materials can help institutions assess how the risks identified at national level relate to their own activities.
Where does Belgium's AML/CFT system still fall short?
One of the report's main concerns is the effectiveness of supervision and enforcement. Although the National Bank of Belgium (NBB) and the Financial Services and Markets Authority (FSMA) have developed risk-based supervisory approaches, FATF identifies areas where supervisory coverage, frequency and effectiveness could be improved. Certain payment and electronic money institutions, as well as some entities supervised by the FSMA, require particular attention. Institutions in those categories should read the supervisory findings as addressed to them rather than to the banking sector alone.
The NBB's guidance on its AML/CFT supervisory powers and policy explains the Bank's role in monitoring compliance, conducting off-site and on-site supervision, and imposing administrative sanctions where appropriate. The FSMA's AML/CFT resources provide further information on the requirements applicable to entities under its supervision.
The evaluation also points to limitations in the deterrent effect of sanctions. Where sanctions are limited or their publication is restricted, their ability to encourage compliance across the sector may be weakened.
Another important issue concerns the quality and timeliness of suspicious transaction reporting. While the reporting framework is generally considered satisfactory for credit institutions, delays and shortcomings in the quality of reports remain areas for improvement. Financial intelligence is only as useful as the information provided, making accurate, timely and sufficiently detailed reporting essential. CTIF-CFI's guidance on the obligations of reporting entities outlines the relevant responsibilities, including internal controls, ongoing due diligence and the reporting of suspicions.
The ratings weaknesses identified in the report concern new technologies, beneficial ownership transparency and national cooperation, and explain why Belgium remains in enhanced follow-up.
FATF also identifies weaknesses in the reliability of beneficial ownership information. Although registration rates in Belgium's Ultimate Beneficial Owner (UBO) register are high, the absence of systematic verification has affected the accuracy and currency of the information recorded. Shell companies, dormant entities and nominee directors or shareholders may further complicate efforts to establish who ultimately owns or controls a business.
The Belgian authorities provide practical information on registering and updating beneficial ownership information. For obliged entities, however, consulting the register should form part of a wider verification process rather than automatically replacing their own customer due diligence.
Finally, the report highlights the need to strengthen the implementation of targeted financial sanctions and controls relating to terrorist financing and proliferation financing. The European Commission maintains an overview of EU sanctions and related resources, including the consolidated list of individuals, groups and organisations subject to EU financial sanctions. These official resources can support institutions in maintaining appropriate screening arrangements, alongside their applicable legal and supervisory requirements.
What does FATF expect from the private sector in practice?
Although the mutual evaluation assesses Belgium's national AML/CFT system rather than creating a new set of direct obligations for individual institutions, its findings show where obliged entities should examine their existing arrangements. Three expectations run through the report.
The first concerns risk assessment: the national findings on drug trafficking, cash-based activity, fraud, professional money laundering and virtual assets only become operational for an institution once they are translated into its own assessment of customers, products, services, delivery channels and geographical exposure.
The second concerns reporting: FATF notes shortcomings in the quality and timeliness of suspicious transaction reports, a finding about the information institutions provide rather than about the analysis carried out on it, which can only be addressed upstream, in the detection and documentation of suspicion.
The third concerns demonstrated effectiveness: supervisory findings in Belgium increasingly turn on evidence that controls work as intended, which places testing, quality assurance, management information and documented decisions at the centre of the exercise rather than policy documents alone. The sections below examine each of these areas and the requirements that apply to them in Belgium.
Should institutions reassess their money laundering and terrorist financing risk assessments?
Institutions should ensure that their risk assessments reflect the threats identified in the report, including organised crime, cash-based activity, fraud, corruption, cross-border transactions and virtual assets where relevant to their business model. Risks should be assessed in relation to the institution's customers, products, services, delivery channels and geographical exposure. The assessment should also be updated when material changes occur.
European law gives a timetable to that work. Regulation (EU) 2024/1624, the new AML Regulation that forms part of the EU's 2024 anti-money laundering package, applies from 10 July 2027 and makes the institution-wide risk assessment an explicit obligation that must be documented. Institutions preparing their compliance roadmap for 2027 have an interest in aligning their risk assessment methodology now rather than at the deadline.
The NBB's AML/CFT reference documents include Belgian legislation and sectoral risk assessments that can provide further context for institutions subject to its supervision.
Are customer due diligence and beneficial ownership checks sufficiently robust?
The weaknesses identified in the UBO register demonstrate why registration alone should not automatically be treated as sufficient evidence of ownership or control. Institutions should verify beneficial ownership information against reliable sources, investigate inconsistencies and understand the ownership and control structures of legal entities. Enhanced scrutiny may be appropriate where structures are complex, opaque or inconsistent with the customer's stated business activities.
Under the Belgian AML law of 18 September 2017, consulting the register forms part of a wider identification and verification process. It does not relieve an institution of the duty to establish, on the basis of reliable sources, who the beneficial owner is, or of the duty to resolve inconsistencies between the information registered and the customer's documentation. In practice, that means treating register data as one input among several, documenting the checks performed and escalating cases in which the registered information cannot be reconciled with the customer's file.
Can transaction monitoring identify suspicious patterns rather than isolated transactions?
The risks described by FATF highlight the importance of monitoring transactions in context. Institutions should consider whether their systems and procedures can identify unusual patterns, links between apparently unrelated transactions and activity inconsistent with a customer's profile. Relevant indicators may include unexplained cash activity, flows involving higher-risk jurisdictions, unusual business transactions and activity that does not correspond to the customer's declared source of funds.
Institutions should also review their internal escalation procedures to ensure that alerts are investigated promptly and that decisions to file, or not to file, suspicious transaction reports are properly documented.
Are sanctions screening and terrorist financing controls effective?
Institutions should assess whether their screening arrangements, customer data and escalation processes allow them to identify sanctions risks and respond appropriately, and should test their controls to confirm that potential matches are detected and resolved, including where ownership structures are complex or cross-border. Terrorist financing controls should also account for activity involving small amounts or funds from apparently legitimate sources: transaction value alone should not determine whether a case warrants examination. Institutions can consult the European Commission's official sanctions resources when reviewing their screening processes, while ensuring that their controls reflect all applicable legal requirements.
Can institutions demonstrate that staff and controls are effective?
Training should reflect the institution's actual exposure and the risks identified in the evaluation. Employees involved in onboarding, customer due diligence, transaction monitoring and investigations should understand the relevant red flags, internal escalation channels and reporting responsibilities, and should be able to recognise when information is inconsistent, incomplete or insufficient to explain a customer's activity. The broader message of the evaluation is that the existence of a policy or procedure does not, by itself, establish that a risk is adequately managed. Institutions should be able to demonstrate how controls operate in practice through testing, quality assurance, management information, documented decisions and remediation of identified weaknesses. These measures should be proportionate to the institution's size, activities and risk exposure, and should be integrated into its existing AML/CFT governance and control framework.
What happens next for Belgium following the FATF evaluation?
Belgium's enhanced follow-up status means that the country must continue working to address the deficiencies identified by FATF and report on the progress achieved. Under the FATF's follow-up procedures, jurisdictions in enhanced follow-up report back to the plenary, and Belgium's first follow-up report is expected in 2027. The next milestone on the public calendar is the FATF plenary of 26 to 30 October 2026, at the close of which the organisation publishes its decisions.
Priorities include improving the effectiveness of investigations and prosecutions, strengthening supervisory outcomes, enhancing the quality and timeliness of suspicious transaction reporting, improving the reliability of beneficial ownership information and reinforcing the implementation of targeted financial sanctions.
Progress will depend on cooperation between public authorities, law enforcement, supervisors and private-sector entities. Financial institutions play an important role in this process because their customer due diligence, monitoring and reporting activities contribute to the wider system for identifying and disrupting financial crime.
For the private sector, the report is therefore a useful basis for reviewing whether existing controls address the risks encountered in practice, whether identified weaknesses are remediated promptly and whether the effectiveness of those controls can be evidenced.
What should financial institutions take away from the report?
FATF's mutual evaluation presents a mixed picture of Belgium's AML/CFT framework. The country has established a substantial legal and regulatory foundation, but important challenges remain in translating that framework into effective outcomes.
For obliged entities, the practical consequence is a shift in emphasis from documented procedures to evidence that controls work, in the four areas the report itself highlights: beneficial ownership verification, suspicious transaction reporting, the treatment of virtual assets, and the effectiveness of sanctions screening.
