Why now: the dates and their sources

Five public facts in date order, each with its source and the date we checked it. In plain words first, then the precise wording. Our own reading follows separately, marked as ours.

  1. 13 July 2026

    The Dutch central bank fined a payment company EUR 2.65 million because the software that watches customer transactions was not fed properly for over two years and alerts were closed in bulk. The company has objected; the objection was undecided when we checked.

    De Nederlandsche Bank publishes an administrative fine of EUR 2.65 million on a payment institution under Section 3(2) of the Wwft for failing to adequately and continuously monitor transactions.

    DNB, enforcement measure published 13 July 2026Checked 2026-10-15
  2. 18 September 2026

    The EU's banking authority finished its rules on how firms must manage outside providers. Payment and e-money companies are covered, so a firm using a provider like us must assess and document that arrangement.

    The European Banking Authority publishes its final guidelines on third-party risk management. Payment institutions and e-money institutions are in scope.

    EBA, guidelines on third-party risk management, final reportChecked 2026-10-13
  3. 5 October 2026

    The Dutch central bank fined an e-money company EUR 722,160 for not keeping up its ongoing checks on customers between January 2023 and July 2024. The fine was cut by 15 percent because the company accepted the facts.

    De Nederlandsche Bank publishes an administrative fine of EUR 722,160 on an e-money institution for serious shortcomings in the ongoing monitoring of its customers and their transactions between 1 January 2023 and 16 July 2024.

    DNB, enforcement measure published 5 October 2026Checked 2026-10-15
  4. 10 July 2027

    A new EU anti-money-laundering law applies. Every customer must be re-checked at least every five years, and every year if they are higher risk.

    Regulation (EU) 2024/1624, the AML Regulation, applies. Obliged entities must update customer information at least every five years, and at least every year for higher-risk customers.

    EUR-Lex, Regulation (EU) 2024/1624, Articles 26(2) and 90Checked 2026-10-13
  5. 2028

    A new EU authority, AMLA, picks up to 40 of the largest cross-border firms and supervises them directly.

    The Anti-Money Laundering Authority expects to select up to 40 cross-border entities for direct supervision by the end of 2027 and to begin supervising them in 2028.

    AMLA, explainer on direct supervisionChecked 2026-10-13

Our reading

These dates create work. They do not by themselves mean that any firm is non-compliant.

Firms with large, old customer books have to re-check thousands of files before July 2027 to meet the new intervals, on top of the normal yearly cycle, while regulators are already fining for weak checks. That is a shortage of people with a shortage of proof attached. Whether it is painful enough for a firm to change how it does this is the question we are testing with first firms.

Evidence supports a decision. It does not make one. The firm's MLRO keeps the final say on every file. Nikxius is not a law firm, an auditor or a regulator. No folder promises a regulatory outcome. The service is looking for its first firms.

Tell us how your last round of reviews actually went.

Thirty minutes, no slides. Who does the re-checking today, how long it takes, and what the regulator accepted as proof. If your current setup works well, that is a useful answer too.

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Nikxius is run by Nikhil Sood, who replies to every request personally.