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European FIUs Workshop on Harmonising the Data Set for Reporting of Suspicious Activities and related Transaction Records

The Workshop “Review of the Outcomes of the Discussions on the Draft Standardised Minimum Data Set (SMDS) for the Reporting of Suspicious Activity and related Transaction Records”, organised by the Council of Europe’s Economic Crime and Cooperation Division, provided an opportunity for participating European Union (EU) Financial Intelligence Units (FIUs) to review and discuss the draft SMDS for suspicious transaction reports (STRs) and transaction records (TrRs) and the feedback and contributions from private sector received during the previous workshop, held on 20-21 January 2026 in Brussels, Belgium.

The Workshop was organised as a hybrid event and brought together over 20 participants, with representatives of the FIUs from Belgium, France, Germany, Italy, Luxembourg, Malta, the Netherlands and Spain, representatives from the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), the European Commission represented by SG REFORM and DG FISMA.

The discussions were organised mainly around two major topics – progressing the further development of the STR and TrR SMDS for STRs, taking account of feedback from various stakeholders, including representatives from obliged entities in the private sector and technology providers of software related to transaction monitoring

and the submission of STRs on 20-21 January 2026 in Brussels, Belgium. This also included consideration of feedback, discussions and contributions received both during and after the previous workshops, held in November 2025 in Amsterdam, the Netherlands, and September 2025 in Strasbourg, France.

The workshop was organised as an interactive exercise, allowing for breakout sessions and group dialogue, as well as for technical discussions and refinement of datapoints definitions, attributes, enumerations, format and validations rules. The workshop also involved a tour de table, exploring the topic of change readiness, operational transformation and ways in which to assess the possible impact which introducing the use of an SMDS may have on resources, existing processes, and technology-enabled tools for both FIUs and OEs, with a view to compiling a summary of these challenges, for future consideration as part of the ongoing development of the SMDS when transferred to the AMLA Working Group. Finally, a Council of Europe expert presented identified needs for prioritisation of potential changes to systems, as well as follow-up activities and communication strategies accompanying the introduction and operationalisation of the SMDS. This work will be used to generate draft guidelines to support the Implementing Technical Standard (ITS) to be prepared by AMLA under Art. 69(3) of Regulation (EU) 2024/1624.

As the next step, the project will continue work on refining the SMDS, aiming to incorporate the feedback received from FIUs during and after the workshop and to finalise the draft SMDS by the end of the first quarter of 2026, as well as the development of the technical guidelines (instructions) in support of the STR and TrR SMDS governance.

The event was organised within the framework of the Technical Support Instrument initiative “Preparation of a common baseline for an Anti-Money Laundering / Counter Financing of Terrorism Reporting system”, co-funded by the European Commission’s Secretariat-General, Structural Reform and Investment Task Force and the Council of Europe and implemented by the Council of Europe.

 

STARSBOURG, FRANCE 24 – 26 FEBRUARY 2026
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