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title: "Austria (AT) — Financial-Integrity Intelligence · Sentinel"
canonical: https://sentinel.gi/jurisdictions/austria/
source_html: /jurisdictions/austria/index.html
description: "Financial integrity intelligence for Austria (AT): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings."
generated_at: 2026-11-08T04:46:02Z
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# Austria (AT) — Financial-Integrity Intelligence · Sentinel

Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above &ldquo;Probable&rdquo; until stronger sources are retrieved.

Financial Integrity Monitor

# Austria AT

Domains covered

6 of 8

Sources

154

Role actions

8

Horizon <90d

1

Jurisdiction profile

FATF status: Largely Compliant Tier: A Risk direction: Stable Enablement vs enforcement: Mixed

Austria&#x27;s AML/CFT/CPF regime rests on the FMA (financial supervision), the police-based A-FIU, and the WiEReG beneficial-ownership register. More The FATF&#x27;s April 2026 5th-round MER found clear progress on BO transparency and supervision but placed Austria in enhanced follow-up over FIU resourcing, restrictive ML-offence interpretation, weak asset recovery, and fragmented DNFBP supervision.

Key deficiencies

- A-FIU under-resourced with limited budgetary/recruitment independence, narrowly focused on predicate offences rather than complex/cross-border ML
- Restrictive judicial interpretation of the money-laundering offence limits investigation and prosecution volume
- DNFBP supervision (beyond casinos, lawyers, notaries) suffers fragmentation, resource shortages and few remedial actions
- No comprehensive national asset-recovery strategy; confiscation and victim restitution levels low
- Historical precedent of delayed EU AML directive transposition (CJEU referral in 2020 over AMLD4)

Recent developments (18m)

- FATF published Austria&#x27;s 5th-round Mutual Evaluation Report (30 April 2026); Austria placed in enhanced follow-up with a 3-year roadmap of Key Recommended Actions
- Raiffeisen Bank International&#x27;s continued large-scale Russia exposure and Austria&#x27;s October 2025 stalling of the EU&#x27;s 19th Russia sanctions package to secure compensation via unfreezing Deripaska-linked Rasperia assets
- Rene Benko/Signa insolvency-fraud prosecution culminating in a Supreme Court-confirmed 2-year sentence (2 July 2026)
- FMA MiCA transition: only 4 of 13 grandfathered crypto-asset service providers retained authorization by the 31 December 2025 deadline
- EU AMLA became operational (Frankfurt seat, chair appointed) with AMLR/6AMLD implementation pipeline advancing toward 2027 application

Law made at European Economic Area level that applies in Austria is covered once, on the [European Economic Area](/jurisdictions/eea/) page. This page covers Austria&#8217;s own layer: implementation, national authorities, national options and local enforcement.

Brief

## Lead signal

#### Lead Signal

Austria&#x27;s Financial Market Authority (FMA) granted a new Markets in Crypto-Assets Regulation (MiCAR) crypto-asset service provider (CASP) authorisation to MEGE zweite GmbH, operating as BingX EU, by administrative decision dated 13 October 2026 and published 14 October 2026. The authorisation enables EEA-wide passporting of crypto-asset services from an Austrian base, extending a pattern in which the FMA has positioned itself as an active CASP licensing authority within the EU single market. This sits alongside a separate FMA warning, published 6 October 2026, stating that Coinmindz, an entity with a purported Dubai seat, is not authorised to provide licensable securities or investment-advice services in Austria. Read together, the two developments trace a single structural line: the same regulator that is actively licensing crypto-asset business under MiCAR is simultaneously pushing back against unlicensed cross-border solicitation into the Austrian market from a jurisdiction carrying enabler characteristics.

Read full brief

#### Lead Signal

Austria&#x27;s Financial Market Authority (FMA) granted a new Markets in Crypto-Assets Regulation (MiCAR) crypto-asset service provider (CASP) authorisation to MEGE zweite GmbH, operating as BingX EU, by administrative decision dated 13 October 2026 and published 14 October 2026. The authorisation enables EEA-wide passporting of crypto-asset services from an Austrian base, extending a pattern in which the FMA has positioned itself as an active CASP licensing authority within the EU single market. This sits alongside a separate FMA warning, published 6 October 2026, stating that Coinmindz, an entity with a purported Dubai seat, is not authorised to provide licensable securities or investment-advice services in Austria. Read together, the two developments trace a single structural line: the same regulator that is actively licensing crypto-asset business under MiCAR is simultaneously pushing back against unlicensed cross-border solicitation into the Austrian market from a jurisdiction carrying enabler characteristics.

The CASP authorisation is best read as routine, in-force regulatory activity under an established regime rather than a one-off event. Austria&#x27;s MiCAR transposition, implemented through the MiCA-VVG, gives the FMA clear competence as the national authority for crypto-asset service providers, and the BingX EU decision is consistent with the steady throughput of licensing activity that an EU member state with an active CASP pipeline would be expected to generate. The analytical significance lies less in the individual licence than in what it confirms about Austria&#x27;s position in the EU&#x27;s crypto-asset licensing architecture as the regime matures into its post-transition operating phase.

#### Other Developments

Unauthorised solicitation from a third-country seat. The FMA&#x27;s warning against Coinmindz, published 6 October 2026, states that the firm, which claims a Dubai seat, has no authorisation to provide licensable investment-advice or other securities services in Austria. The warning rests on section 3(2)(1) of the Wertpapieraufsichtsgesetz 2018 (WAG 2018), which governs the requirement for authorisation to provide investment advice, with publication grounded in section 92(11) WAG 2018. This is not an isolated incident but part of a recurring pattern in which entities based in jurisdictions with weaker outbound regulatory cooperation solicit Austrian clients into crypto-adjacent investment products without the licence Austrian law requires. The accessory-liability basis cited is specific to the unauthorised provision of investment advice and securities services, distinct from a banking or payments authorisation failure.

Consolidated sanctions and AML supervisory mandate. Since 1 January 2026 the FMA has held unified competence for anti-money-laundering, counter-terrorist-financing, and financial-sanctions oversight across all Austrian financial-market participants, following the transfer of sanctions-monitoring powers previously held by the Oesterreichische Nationalbank (OeNB) under the Sanktionengesetz 2024 (Sanctions Act 2024). A law-firm briefing dated 15 October 2026 restates this consolidated mandate without adding new legal content; the underlying fact of the FMA&#x27;s unified competence is itself confirmed directly on the FMA&#x27;s own published materials, so the restatement carries probable rather than confirmed status as new information this cycle, while the underlying structural fact of consolidation remains well evidenced.

#### Cross-Monitor Connections

The Coinmindz warning and the pattern of unauthorised cross-border crypto-investment solicitation it represents is directly relevant to the World Payments Monitor&#x27;s conduct and financial-promotions tracking, where unauthorised-provider warnings issued by the FMA form a recurring enforcement signal independent of the crypto-specific framing applied here. The MiCAR CASP authorisation granted to MEGE zweite GmbH also connects to the crypto monitor&#x27;s own licensing-regime tracking, since the same underlying administrative decision evidences both the FMA&#x27;s active role as a MiCAR competent authority and the broader financial-integrity significance of an expanding, EEA-passportable crypto-asset-service footprint originating from Austria. Neither connection is elaborated further here; it is flagged as a routing point for monitors tracking the respective domains directly.

#### Outlook

The FMA&#x27;s dual posture, active CASP licensing on one hand and continued enforcement against unauthorised cross-border solicitation on the other, is likely to persist as the structural baseline for Austria&#x27;s financial-integrity profile through the remainder of 2026. No Austria-specific sanctions-evasion, beneficial-ownership, conflict-finance, or compliance-technology development was identified this cycle, consistent with a stable regime rather than one undergoing structural change in those areas. The enabler-jurisdiction exposure signalled by the Coinmindz warning bears watching: whether this is an isolated solicitation attempt or part of a recurring inflow of unlicensed third-country crypto-investment offers into the Austrian market will depend on whether further FMA warnings naming similarly structured entities emerge in coming cycles.

Earlier periodic briefs (6) 25 Oct 2026 · fim-2026-10-25

#### Lead Signal

Austria&#x27;s Financial Market Authority (FMA) granted a new Markets in Crypto-Assets Regulation (MiCAR) crypto-asset service provider (CASP) authorisation to MEGE zweite GmbH, operating as BingX EU, by administrative decision dated 13 October 2026 and published 14 October 2026. The authorisation enables EEA-wide passporting of crypto-asset services from an Austrian base, extending a pattern in which the FMA has positioned itself as an active CASP licensing authority within the EU single market. This sits alongside a separate FMA warning, published 6 October 2026, stating that Coinmindz, an entity with a purported Dubai seat, is not authorised to provide licensable securities or investment-advice services in Austria. Read together, the two developments trace a single structural line: the same regulator that is actively licensing crypto-asset business under MiCAR is simultaneously pushing back against unlicensed cross-border solicitation into the Austrian market from a jurisdiction carrying enabler characteristics.

The CASP authorisation is best read as routine, in-force regulatory activity under an established regime rather than a one-off event. Austria&#x27;s MiCAR transposition, implemented through the MiCA-VVG, gives the FMA clear competence as the national authority for crypto-asset service providers, and the BingX EU decision is consistent with the steady throughput of licensing activity that an EU member state with an active CASP pipeline would be expected to generate. The analytical significance lies less in the individual licence than in what it confirms about Austria&#x27;s position in the EU&#x27;s crypto-asset licensing architecture as the regime matures into its post-transition operating phase.

#### Other Developments

Unauthorised solicitation from a third-country seat. The FMA&#x27;s warning against Coinmindz, published 6 October 2026, states that the firm, which claims a Dubai seat, has no authorisation to provide licensable investment-advice or other securities services in Austria. The warning rests on section 3(2)(1) of the Wertpapieraufsichtsgesetz 2018 (WAG 2018), which governs the requirement for authorisation to provide investment advice, with publication grounded in section 92(11) WAG 2018. This is not an isolated incident but part of a recurring pattern in which entities based in jurisdictions with weaker outbound regulatory cooperation solicit Austrian clients into crypto-adjacent investment products without the licence Austrian law requires. The accessory-liability basis cited is specific to the unauthorised provision of investment advice and securities services, distinct from a banking or payments authorisation failure.

Consolidated sanctions and AML supervisory mandate. Since 1 January 2026 the FMA has held unified competence for anti-money-laundering, counter-terrorist-financing, and financial-sanctions oversight across all Austrian financial-market participants, following the transfer of sanctions-monitoring powers previously held by the Oesterreichische Nationalbank (OeNB) under the Sanktionengesetz 2024 (Sanctions Act 2024). A law-firm briefing dated 15 October 2026 restates this consolidated mandate without adding new legal content; the underlying fact of the FMA&#x27;s unified competence is itself confirmed directly on the FMA&#x27;s own published materials, so the restatement carries probable rather than confirmed status as new information, while the underlying structural fact of consolidation remains well evidenced.

#### Cross-Monitor Connections

The Coinmindz warning and the pattern of unauthorised cross-border crypto-investment solicitation it represents is directly relevant to the World Payments Monitor&#x27;s conduct and financial-promotions tracking, where unauthorised-provider warnings issued by the FMA form a recurring enforcement signal independent of the crypto-specific framing applied here. The MiCAR CASP authorisation granted to MEGE zweite GmbH also connects to the crypto monitor&#x27;s own licensing-regime tracking, since the same underlying administrative decision evidences both the FMA&#x27;s active role as a MiCAR competent authority and the broader financial-integrity significance of an expanding, EEA-passportable crypto-asset-service footprint originating from Austria. Neither connection is elaborated further here; it is flagged as a routing point for monitors tracking the respective domains directly.

#### Outlook

The FMA&#x27;s dual posture, active CASP licensing on one hand and continued enforcement against unauthorised cross-border solicitation on the other, is likely to persist as the structural baseline for Austria&#x27;s financial-integrity profile through the remainder of 2026. No Austria-specific sanctions-evasion, beneficial-ownership, conflict-finance, or compliance-technology development was identified, consistent with a stable regime rather than one undergoing structural change in those areas. The enabler-jurisdiction exposure signalled by the Coinmindz warning bears watching: whether this is an isolated solicitation attempt or part of a recurring inflow of unlicensed third-country crypto-investment offers into the Austrian market will depend on whether further FMA warnings naming similarly structured entities emerge in coming cycles.

11 Oct 2026 · fim-2026-10-11

#### Lead Signal

Austria&#x27;s financial-integrity architecture moved on two fronts at once this cycle. The Financial Market Authority (FMA) formally consolidated sanctions-compliance supervision away from the Austrian National Bank (OeNB), effective 1 January 2026, under the Sanktionengesetz 2024 (SanktG 2024), which replaced the SanktG 2010. The new regime widens the FMA&#x27;s supervisory perimeter beyond banks to insurance undertakings, investment firms, alternative investment fund managers, electronic money institutions and crypto-asset service providers, with frozen-funds reporting now owed to the FMA without undue delay and on a quarterly cycle. This is a structural centralisation, not an incident: a single conduct-and-prudential supervisor now also owns sanctions compliance across a cross-sectoral population of obliged entities, closing a gap in which sanctions oversight sat apart from the FMA&#x27;s existing AML/CTF and licensing remit.

Alongside the sanctions reorganisation, Austria&#x27;s 2026 FATF mutual evaluation, adopted at the February 2026 Plenary and published 30 April 2026, rated the country Compliant or Largely Compliant on all but one of the 40 FATF Recommendations. The report&#x27;s Key Recommended Actions concentrate on the capacity of the Financial Intelligence Unit and law enforcement to handle complex money-laundering investigations and asset confiscation, rather than on technical-compliance gaps in the legal framework itself. Austria is not on the FATF grey list. Read together, the two developments describe a jurisdiction whose architecture is well-rated on paper but whose enforcement capacity, particularly for complex cases, is the FATF&#x27;s own flagged weak point.

#### Other Developments

FMA enforcement against crypto-asset firms intensified. The FMA issued its first published legally-binding MiCA penalty in Austria, fining Bitpanda GmbH €70,000 for failing to submit its crypto-asset white paper the required number of working days ahead of publication and for premature or non-compliant marketing communications. Separately, Kurant GmbH was fined €45,000 under the FM-GwG for deficient written customer due diligence and ongoing-monitoring procedures covering occasional transactions and suspected money-laundering or terrorist-financing cases — the second fine against the firm in under a year, following a €70,000 penalty in October 2025. Taken together the two decisions indicate the FMA treating crypto-asset supervision as an active enforcement line rather than a dormant licensing formality, though the Kurant finding rests on a single secondary source and no FMA primary notice confirming the penal order as final was retrieved this cycle.

Beneficial-ownership architecture held stable and was positively assessed. The 2026 FATF mutual evaluation rated Austria&#x27;s WiEReG Beneficial Ownership Register a key strength of the national AML/CFT system. The most recent structural change to the register, a nominee-agreement reporting amendment effective 1 October 2025, remains the latest development; no further amendment was located this cycle.

#### Cross-Monitor Connections

The FMA&#x27;s enforcement activity against Bitpanda and Kurant is directly relevant to the World Payments Monitor&#x27;s stablecoin and digital-money tracking, where the same supervisory posture toward non-compliant crypto-asset activity is visible from a payments-infrastructure angle. The sanctions-supervision consolidation under the SanktG 2024 also touches the crypto monitor&#x27;s licensing coverage, since crypto-asset service providers are now explicitly within the FMA&#x27;s sanctions-compliance perimeter alongside banks and other financial institutions. On the AML/CTF regime, Austria&#x27;s position as an EU-27 state means it is bound directly by the EU AML Regulation (AMLR) when it applies; no Austria-specific Sixth Anti-Money Laundering Directive transposition instrument or AMLA direct-supervision designation was located this cycle, a gap that will matter increasingly as the EU AML Package&#x27;s supervisory perimeter takes shape.

#### Outlook

The near-term signal to watch is whether the FMA follows the Bitpanda and Kurant penalties with further published enforcement decisions, which would confirm a sustained rather than episodic posture toward crypto-asset supervision. On the sanctions side, the consolidation under the FMA is now in force and the practical test will be whether frozen-funds reporting and cross-sectoral supervision actually extend evenly across the newly added sectors — insurance, investment firms, AIFMs and EMIs — or concentrate on the already-familiar banking population. The FATF&#x27;s Key Recommended Actions on FIU and law-enforcement capacity for complex investigations and asset confiscation are the structural item most likely to generate follow-on reporting, since they identify a capacity question rather than a legal-framework gap that a single statutory amendment could resolve.

4 Oct 2026 · fim-2026-10-04

#### Lead Signal

Austria&#x27;s Finanzausschuss (parliamentary finance committee) advanced two connected pieces of legislation on 29 September 2026, both now headed to the Nationalrat. The first is a novelle harmonising and strengthening the legal framework for Austria&#x27;s register of beneficial owners, carried with cross-party support from OVP, SPO, NEOS and FPO. The second is a bill transposing CRD VI (Directive 2013/36/EU as amended by (EU) 2024/1619) that strengthens the independence of the Finanzmarktaufsicht, introducing mandatory cooling-off periods for board members, annual interest declarations, a 14-year cap on board tenure, and a new duty for credit institutions to notify the FMA before executing transactions deemed prudentially relevant, so that the FMA can carry out a money-laundering and terrorist-financing risk assessment before the transaction proceeds. Together these measures tighten the national interconnection layer against the EU-wide beneficial-ownership-register architecture and reduce institutional-capture risk inside Austria&#x27;s financial supervisor, moving in the same direction as the broader EU AML Package even though neither instrument has yet reached the Nationalrat floor.

The structural significance sits above the enforcement volume. Austria has not generated a new sanctions-designation delta or a fresh AML fine this cycle; instead, two architecture-level bills advanced through committee on the same day, both aimed at strengthening institutional integrity rather than reacting to a specific incident. That is the more durable signal: a jurisdiction choosing to tighten its own oversight architecture ahead of being compelled to.

#### Other Developments

FMA sanctions-supervision consolidation remains the operative baseline. Since 1 January 2026, the FMA has held consolidated supervision and enforcement of national and EU/UN financial sanctions, including those concerning Russia and Iran, having absorbed this mandate from the Oesterreichische Nationalbank under the Sanktionengesetz 2024. The consolidated mandate now extends to payment institutions, e-money institutions and crypto-asset service providers in addition to banks and insurers. No new designation event altered this baseline in the current cycle, but it is the backdrop against which the new credit-institution notification duty under the CRD VI transposition bill should be read: a single supervisor now holds both the sanctions-screening mandate and the incoming pre-transaction AML/CFT assessment function for prudentially relevant transactions.

Austria&#x27;s FATF Mutual Evaluation Report continues to anchor the AML/CFT baseline. Adopted at the February 2026 plenary and published 30 April 2026, the report found Austria largely compliant or compliant across most Recommendations and did not place the country on the grey list, while flagging FIU operational capacity and asset-confiscation effectiveness as areas needing improvement. No new FATF plenary action touched Austria this cycle, so the MER stands as the operative reference point against which the current legislative tightening is measured.

FMA&#x27;s first legally final MiCAR enforcement decision continues to anchor the crypto-enforcement posture. Published 14 August 2026, the decision fined Bitpanda GmbH EUR 70,000 for a late whitepaper notification, a premature marketing communication, and missing mandatory disclosures. This predates the current cycle&#x27;s window but remains the standing precedent establishing that Austria&#x27;s crypto-asset supervision under MiCAR is enforcement-active rather than merely declaratory.

#### Cross-Monitor Connections

The beneficial-ownership-register novelle sits directly at the interconnection layer the World Payments Monitor and the Crypto monitor also track from their own angles: the same Finanzausschuss session that advanced the BO-register novelle also advanced the FMA-independence bill carrying the pre-transaction notification duty for credit institutions, a licensing and market-access development with payments-sector implications. The FMA&#x27;s consolidated sanctions-supervision mandate, covering payment institutions, e-money institutions and crypto-asset service providers, is likewise the shared substrate beneath both the World Payments and Crypto monitors&#x27; coverage of Austria&#x27;s institutional architecture. Readers tracking Austria&#x27;s digital-asset posture should note that the Bitpanda MiCAR fine establishes the enforcement baseline that the Crypto monitor&#x27;s own licensing module addresses in greater depth.

#### Outlook

Both bills now move to the Nationalrat, where passage would complete Austria&#x27;s current round of CRD VI transposition and BO-register harmonisation. The AMLA direct-supervision selection exercise, whose provisional list of eligible cross-border groups was due by the end of September 2026, has not yet been confirmed as published; whether any Austria-headquartered or Austria-branch financial group will fall under direct AMLA supervision from January 2028 depends on that list. Until the provisional list is confirmed, Austria&#x27;s AML/CFT architecture should be read as tightening at the national level while the EU-level supervisory perimeter remains undetermined for Austrian entities specifically.

28 Sep 2026 · fim-2026-09-28

#### Lead Signal

Austria&#x27;s financial-integrity picture this cycle is defined by a structural finding rather than a single incident: the FATF adopted its 2026 mutual evaluation of Austria at the February 2026 Plenary, crediting clear progress on beneficial-ownership transparency and financial-sector supervision, but placing the country in enhanced follow-up on the strength of insufficient FIU, law-enforcement and prosecutorial capacity to investigate and prosecute sophisticated money laundering. This is a durable capacity finding, not a one-off enforcement gap, and it sets the frame for everything else this cycle touches.

That frame is reinforced by a disclosed episodic event: Austrian authorities dismantled a Vienna-based sanctions-evasion network that supplied CNC machines and metalworking tools to Russia in breach of EU Regulation 833/2014, rerouting deliveries through seven third countries and exceeding EUR 3.3 million in value since 2022. The managing director, a Belarusian national, was arrested in May 2026. Read together with the FATF finding, the pattern is one of a well-resourced formal architecture — MiCA licensing, sanctions statutes, beneficial-ownership registers — operating alongside acknowledged gaps in the capacity to prosecute the most sophisticated flows through that architecture.

#### Other Developments

Sanctions-authority consolidation. Effective 1 January 2026, the FMA assumed full responsibility for monitoring and enforcing international financial sanctions across the Austrian financial sector, a function previously distributed with the OeNB. This consolidates sanctions and AML/CFT oversight within a single authority, a structural change to Austria&#x27;s institutional architecture that predates and frames the Vienna evasion-network disclosure.

Beneficial-ownership register access remains restrictive. The 6AMLD beneficial-ownership register access-rule transposition deadline of 10 July 2026 applies to Austria. Austria amended its WiEReG register on 1 October 2025 ahead of that deadline, but the register continues to operate on a case-by-case, fee-based model (EUR 4 per entry) rather than moving to general public access or the harmonised mutual-recognition standard 6AMLD contemplates. This sits in tension with the FATF MER&#x27;s crediting of clear progress on BO transparency — progress on data existing is not the same as progress on access being opened.

MiCA transition proceeding on schedule. Austria&#x27;s pre-MiCA VASP grandfathering window under the FM-GwG expires 30 June/1 July 2026, and the FMA has begun granting full MiCA CASP authorisations, including to WhiteBIT and Bitpanda. This is a functioning transition rather than a supervisory gap: firms are moving from national registration to full EU-harmonised licensing on the timetable the regulation contemplates.

#### Cross-Monitor Connections

The Vienna sanctions-evasion network intersects directly with WPM&#x27;s payments and correspondent-banking coverage: a seven-country routing chain for goods procurement implies a parallel financial routing question — how the underlying payments for over EUR 3.3 million in deliveries cleared through that chain — that sits outside this cycle&#x27;s evidence base but is a natural next-cycle question for a payments-architecture lens. The FMA&#x27;s sanctions-authority consolidation is also relevant to WPM&#x27;s licensing and market-access coverage of Austrian payment institutions, since a single consolidated supervisor now carries both prudential and sanctions-compliance oversight for the same regulated population. Separately, the crypto monitor&#x27;s coverage of Austria&#x27;s MiCA CASP transition and this monitor&#x27;s D5 finding describe the same underlying regulatory event from different lenses; readers tracking both should expect convergent, not divergent, timelines.

#### Outlook

Austria now enters a structured FATF enhanced-follow-up reporting cycle, expected through 2027, on AML/CFT effectiveness improvements — principally FIU and prosecutorial capacity. Separately, the 6AMLD transposition clock continues to run, with full transposition and the AMLA supervisory perimeter pending 10 July 2027; whether Austria&#x27;s WiEReG access model moves toward the harmonised standard before then, or remains at odds with it, is the concrete BO-transparency question to watch. On sanctions, the FMA&#x27;s newly consolidated authority will be tested by how it handles any further disclosures in the wake of the Vienna network case.

21 Sep 2026 · fim-2026-09-21

#### Lead Signal

Austria&#x27;s Finanzmarktaufsicht (FMA) became, as of 1 January 2026, the sole supervisor for both anti-money laundering/counter-terrorist-financing (AML/CFT) and financial sanctions across the country&#x27;s financial market participants, under the newly adopted Sanctions Act 2024 (Sanktionengesetz 2024), which replaces the Sanctions Act 2010. The consolidation extends explicit supervisory coverage to credit and financial institutions, payment institutions, investment firms, alternative investment fund managers, insurers, and crypto-asset service providers, closing an institutional seam that previously distributed sanctions and AML/CFT oversight across separate structures. This is an architecture story, not an incident: the significance lies in the structural closing of a fragmentation gap rather than in any single enforcement action.

The consolidation&#x27;s timing is notable against a second development this cycle: Austria&#x27;s 2026 FATF mutual evaluation found clear progress in strengthening the country&#x27;s AML/CFT legal and regulatory framework, yet placed Austria in enhanced follow-up. The unresolved issue is not architecture but capacity — the operational resources of the Financial Intelligence Unit, law enforcement, and prosecution services need to be increased, a gap independently corroborated by an IMF publication of the same underlying assessment. Austria has therefore closed a structural seam at the supervisory level while an unresolved capacity gap in investigation and prosecution — flagged since 2016 — persists at the enforcement-delivery level.

#### Other Developments

Sparkasse Oberösterreich Bank AG fine. The FMA imposed a EUR 60,000 fine on Sparkasse Oberösterreich Bank AG for breach of AML/CFT due-diligence obligations. This is a routine, single-source enforcement action rather than evidence of a systemic control gap on its own, but it sits within the same due-diligence framework the FATF evaluation and IMF assessment scrutinised at the national level, illustrating that individual-institution enforcement continues alongside the structural consolidation described above.

Crypto-asset service providers folded into unified sanctions supervision. The FMA&#x27;s expanded sanctions-supervision mandate under the Sanctions Act 2024 explicitly integrates crypto-asset service providers into the same unified sanctions-screening architecture used for banks and payment institutions. This is a deliberate extension of the consolidated supervisory perimeter to a sector that, in many jurisdictions, sits outside mainstream sanctions-screening obligations; Austria&#x27;s approach brings CASPs inside the one-stop-shop framework from the outset rather than layering crypto-specific rules on afterward.

#### Cross-Monitor Connections

The FMA&#x27;s sanctions/AML consolidation and the CASP integration into that same architecture both carry direct relevance for institutions operating payment rails and crypto infrastructure in Austria, a natural point of connection to payments-monitor findings on Austrian licensing activity this cycle. The FATF enhanced-follow-up placement, grounded in unresolved investigation and prosecution capacity rather than in the supervisory architecture itself, is the kind of structural, capacity-level finding that connects to broader conflict-finance and enabler-jurisdiction analysis elsewhere in the fleet, even though no AT-specific enabler-jurisdiction or conflict-finance material surfaced independently this cycle.

#### Outlook

The FATF&#x27;s roadmap for Austria runs through a multi-year follow-up period in which the country must report progress against the recommended actions identified in the 2026 mutual evaluation, with supervisory and prosecutorial resourcing expected to increase over that period. Whether the FMA&#x27;s newly consolidated architecture translates into improved ML investigation and prosecution outcomes — the specific gap that kept Austria in enhanced follow-up despite the acknowledged progress on the legal and regulatory framework — is the central question to track. The CASP integration into unified sanctions supervision is also worth monitoring for how it interacts with Austria&#x27;s broader crypto-asset licensing activity under MiCA.

14 Sep 2026 · fim-2026-08-17

#### Lead Signal

The Financial Market Authority of Austria (FMA) assumed full sanctions-monitoring competence from the Oesterreichische Nationalbank effective 1 January 2026, consolidating a supervisory function previously split between the two institutions and extending its perimeter to cover the entire Austrian financial sector, including crypto-asset service providers, investment firms, and other non-bank obliged entities. Within months of that consolidation, the domestic security service of Austria dismantled a Vienna-registered shell company that had rerouted sanctioned CNC machine tools worth more than EUR 3.3 million to Rostec, the state-owned defence conglomerate of Russia, since 2019, moving the goods through a transshipment chain spanning Turkey, the United Arab Emirates, Hong Kong, Belarus, Kyrgyzstan, South Korea, Poland, and Lithuania before a Belarusian director was arrested on 13 May 2026.

The sequencing is the analytically significant fact. A structural strengthening of the sanctions-enforcement architecture of Austria coincided with the exposure of a mature, multi-jurisdiction evasion pathway that had operated undetected for roughly five years, supplying components assessed as relevant to cruise-missile and combat-aircraft engine production. Read together, the two developments describe an enforcement system whose institutional capacity is improving even as the third-country transshipment corridors it must police remain demonstrably exploitable. Assessed confidence on this reading is High, given multi-source corroboration across a primary FMA announcement and independent reporting on the dismantling of the network.

#### Other Developments

Beneficial-ownership transparency widened ahead of the EU deadline. The FM-GwG-Anpassungsgesetz, effective 1 January 2026, extended the targeted-financial-sanctions risk-assessment duty of Austria from a proliferation-financing-only requirement to cover all sanctions regimes and the full population of obliged entities under the FM-GwG, and amended the WiEReG beneficial-ownership register regime to require disclosure of nominee and trustee arrangements in line with FATF guidance. The amendment is the national transposition delta of Austria layered onto the EEA-wide AML Regulation and sixth AML Directive baseline, closing a gap FATF had previously flagged, ahead of the 10 July 2026 deadline for further 6AMLD beneficial-ownership register development.

FATF placed Austria in enhanced follow-up. The fifth-round mutual evaluation of Austria, an IMF-led assessment adopted at the February 2026 FATF Plenary and published 30 April 2026, found progress on beneficial-ownership transparency and financial-sector supervision but persistent weaknesses in money-laundering investigation and prosecution capacity, and placed the country in enhanced follow-up. The core criticism is substantially unchanged from the 2016 mutual evaluation of Austria, indicating a structural under-resourcing of the investigative and prosecutorial function that institutional reforms to sanctions supervision have not yet reached.

The first published MiCA penalty in Austria landed against Bitpanda. The FMA fined Bitpanda GmbH EUR 70,000 for failing to submit a crypto-asset white paper twenty working days ahead of publication and for circulating a premature marketing communication, disclosed 11 August 2026. The action is assessed rather than high confidence, since it is corroborated only by two independent tier-three outlets and no primary FMA press release was located this cycle; it nonetheless marks the first published enforcement precedent under the Markets in Crypto-Assets Regulation in Austria, arriving as the EU-wide MiCA transitional authorisation regime for crypto-asset service providers has expired.

Cambodia exited the FATF grey list. At the same February 2026 Plenary that adopted the mutual evaluation of Austria, FATF removed Cambodia from its list of jurisdictions under increased monitoring, following action-plan progress on the AML/CFT/CPF deficiencies that triggered its 2019 listing, which centred on casino-linked money-laundering vulnerability.

#### Cross-Monitor Connections

The dismantled Rostec-linked procurement network carries direct relevance beyond the domain trackers of FIM itself. Its dual-use CNC-machine-tool cargo and its role in financing Russian military-industrial production place it squarely within the conflict-finance remit of SCEM, flagged at high severity, while the transshipment corridor routed through Hong Kong, Turkey, and Kyrgyzstan is relevant to the commodity and export-control tracking of ERM at medium severity. The FM-GwG-Anpassungsgesetz of Austria, as a live instance of Member-State transposition activity adjacent to the AML Regulation and sixth AML Directive, is flagged to ESA at medium severity as a data point in the uneven implementation landscape of the EU. And continued detection of Russia sanctions-evasion activity inside an EU Member State, four years into the war, is flagged to GMM at medium severity as a signal bearing on the macro-level efficacy of the sanctions regime itself.

#### Outlook

Three items sit on the near-term horizon. The absorption by the FMA of the sanctions-monitoring mandate is unlikely to be a one-off consolidation; the authority has already issued extensive information requests across the supervised population in the first half of 2026, and further follow-through enforcement activity is plausible as that oversight matures. Separately, the 10 July 2026 deadline for further 6AMLD beneficial-ownership register development falls due against a backdrop in which the AT-specific implementing measures of Austria for that sub-deadline have not been separately confirmed this cycle, leaving open whether the already-enacted WiEReG nominee-disclosure amendment satisfies the fuller register-interconnection obligations coming into force. Further out, the full direct applicability of the AML Regulation from July 2027 will displace the national-transposition model Austria currently operates under FM-GwG, replacing jurisdiction-specific CDD and EDD variance with a single EU-wide rulebook, a structural shift assessed, not yet observed, and carrying a quarter-level uncertainty band on timing. A further MiCA enforcement precedent in Austria, building on the Bitpanda action, is also plausible as the supervised crypto-asset population of the FMA expands following the end of the EU-wide transitional authorisation window. None of this constitutes a prediction; it is the set of scheduled or plausible developments against which the findings of the next cycle should be read.

Domain intelligence (D1–D8)

#### Sanctions Architecture and Evasion

Austria&#x27;s sanctions-architecture picture this cycle is defined by the coincidence of an institutional consolidation and a mature evasion network&#x27;s exposure. Effective 1 January 2026, full sanctions-monitoring competence transferred from the Oesterreichische Nationalbank to the FMA, which now supervises the entire Austrian financial sector for sanctions compliance, including crypto-asset service providers that previously sat outside a unified sanctions-monitoring perimeter. This is a structural change in enforcement architecture, not an incremental adjustment: a single regulator now holds both the mandate and, per the domain tracker, the practical tooling — extensive information requests were issued to the newly expanded supervised population across the first half of 2026.

Continue reading That consolidation sits alongside the dismantling of a Vienna-registered shell-company network that had, since 2019, rerouted sanctioned CNC machine tools worth over EUR 3.3 million to Russia&#x27;s Rostec. The routing architecture is itself the analytically significant element: goods moved through Turkey, the UAE, Hong Kong, Belarus, Kyrgyzstan, South Korea, Poland and Lithuania before reaching their end use, a chain spanning eight jurisdictions across three continents that evidently defeated EU Regulation 833/2014 export controls for roughly six years before a Belarusian director was arrested on 13 May 2026 and the case was disclosed on 11 August 2026. The seizure of EUR 140,000 in assets is a fraction of the estimated EUR 3.3 million total value moved, underscoring that enforcement recovery lagged well behind the network&#x27;s operational lifespan.

Read as an architecture question rather than an incident, the case demonstrates two things simultaneously. First, third-country transshipment remains a durable evasion vector for EU-origin dual-use goods destined for sanctioned end users — the routing through Hong Kong, Kyrgyzstan and Belarus in particular illustrates how jurisdictions with lighter trade-documentation scrutiny function as connective tissue in a broader evasion chain, independent of any single jurisdiction&#x27;s own sanctions posture. Second, the fact that Austria&#x27;s own domestic architecture caught the network only after institutional consolidation, and only after roughly six years of undetected operation, suggests the earlier split supervisory model between the OeNB and other authorities was itself part of the detection gap the FMA&#x27;s new mandate is designed to close. The FMA&#x27;s expanded remit — reaching crypto-asset service providers as well as banks and investment firms — is also structurally relevant given how procurement networks of this type increasingly intersect with digital-asset settlement rails, even though this specific case is not documented as having used crypto payment channels.

The evidentiary base for the network dismantlement itself rests on tier-three reporting (Brussels Signal, corroborated by Reuters coverage), while the FMA mandate transfer is documented via a tier-one FMA source. This asymmetry matters for calibration: the structural regulatory change is High confidence on primary-source grounds, while the operational specifics of the evasion network, though also assessed at High confidence given multi-source corroboration, derive from investigative and legal-blog reporting rather than a primary law-enforcement disclosure.

#### Outlook

The immediate question for the next cycle is whether the FMA&#x27;s sanctions-competence consolidation produces further enforcement outcomes beyond this single case, or whether the Rostec network dismantlement proves to be an isolated data point surfaced during the transition rather than the first of a pattern. The extensive information requests already issued to the expanded supervised population in the first half of 2026 suggest an active supervisory posture is underway, and the results of that activity — additional designations, further network disclosures, or confirmation that the information-request campaign surfaces no further material findings — would materially inform whether Austria&#x27;s sanctions architecture has genuinely closed the detection gap that allowed a six-year evasion scheme to operate, or whether similar undetected networks remain active. No further sanctions-architecture developments beyond this case were located this cycle, and the record should not be read as implying resolution of the broader third-country transshipment vulnerability the case exposed.

Baseline-Tracked Domains with No Current-Cycle Escalation (2 of 8)
- D6 Compliance Technology & Active Defence: Standing coverage — no activity this cycle.
- D8 Commercial Activity: Standing coverage — no activity this cycle.

Regulatory horizon

Adopted 2026-Q4 · ±quarter

### AT beneficial-ownership-register novelle and FMA-independence bill (621 d.B.) advance

FMA board members gain mandatory cooling-off periods and annual interest declarations; the BO register&#x27;s legal framework is harmonised; credit institutions gain a new pre-transaction notification duty for prudentially-relevant transactions subject to FMA AML/CFT assessment.

[Austrian Finanzausschuss / Nationalrat Source](https://www.ots.at/presseaussendung/OTS_20260929_OTS0137/finanzausschuss-fuer-neue-regeln-zu-fma-und-registern-wirtschaftlicher-eigentuemer)

In Force Pending 2027-Q3 · ±quarter

### AMLR full direct applicability

National-level AML rule variance for AT obliged entities is replaced by the EU-wide single rulebook.

[European Union Source](https://www.regpulse.io/blog/eu-aml-package-2026)

Consultation 2028-Q1 · ±year

### AMLA direct-supervision selection exercise

Selected cross-border financial groups move from purely national FMA supervision to direct AMLA supervision for AML/CFT purposes.

[AMLA (EU) Source](https://fiaumalta.org/news/amla-direct-supervision-key-preparatory-steps-ahead-of-2027-selection-exercise/)

Adopted 2029 · ±multi_year

### FATF Key Recommended Actions (3-year roadmap post-2026 MER)

Austria must report back to FATF on progress against the roadmap; supervisory and prosecutorial resourcing is expected to increase over the follow-up period.

[FATF Source](https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-austria-2026.html)

4 dated · 3 pending date · baseline fim-2026-07-08

Role action cards

MLRO

### FMA warned against an unauthorised Dubai-seated crypto/investment offeror while consolidating its own AML and sanctions supervisory mandate.

The Coinmindz warning signals continued unlicensed cross-border solicitation into the Austrian market, relevant to screening and onboarding due diligence where a counterparty&#x27;s exposure to such unauthorised offers is in question. The FMA&#x27;s unified AML/CFT and sanctions mandate since 1 January 2026 means any related suspicious-activity concerns now route through a single consolidated Austrian authority.

2 evidence refs

Compliance

### FMA granted a new MiCAR CASP authorisation and reiterated its consolidated AML/sanctions mandate this cycle.

The MEGE zweite GmbH (BingX EU) authorisation confirms the FMA&#x27;s active role in MiCAR licensing, relevant to firms assessing the Austrian licensing environment as a benchmark or venue. The FMA&#x27;s consolidated supervisory mandate since 1 January 2026 is a structural fact relevant to compliance program design for Austrian-facing institutions.

2 evidence refs

Legal

### FMA&#x27;s publication of the Coinmindz warning rests on specific statutory bases under WAG 2018.

The warning cites section 3(2)(1) and section 92(11) WAG 2018 as its legal basis, relevant to assessing accessory-liability exposure for any Austrian-facing intermediary found to have facilitated access to the unauthorised offeror.

1 evidence refs

Board

### Austria continues to license crypto-asset service providers under MiCAR, while policing unauthorised solicitation.

The dual posture, active licensing combined with enforcement against unlicensed offerors, is a structural feature of Austria&#x27;s financial-market oversight relevant to strategic decisions about operating or partnering with the FMA as a licensing authority.

1 evidence refs

CTO

### A new MiCAR-authorised crypto-asset service provider gained EEA-wide passporting from an Austrian base this cycle.

The BingX EU authorisation is relevant to technical architecture decisions for firms assessing Austria as an EEA passporting base for crypto-asset infrastructure under MiCAR.

1 evidence refs

Risk

### Enabler-jurisdiction exposure persists via unlicensed solicitation from a Dubai-seated entity into the Austrian market.

The Coinmindz warning is a discrete data point in a broader enabler-jurisdiction exposure pattern; whether it recurs with further similarly structured entities bears on risk-concentration assessments for Austrian-facing exposure.

1 evidence refs

Operations

### No material change for this persona this cycle.

No material change for this persona this cycle

Audit

### FMA&#x27;s consolidated AML/sanctions mandate since 1 January 2026 remains the controlling supervisory architecture.

The consolidation of sanctions-monitoring powers from the OeNB into the FMA under the Sanktionengesetz 2024 is relevant to audit scoping of how Austrian-facing AML and sanctions controls are tested against a single consolidated authority rather than a split regime.

1 evidence refs

Scenario sketches

### Illustrative AMLA transition and cross-border obliged-entity supervision

As an illustrative orientation only, the gradual shift from purely national AML/CFT supervision toward AMLA direct and indirect supervision of cross-border obliged entities, under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly-applicable AML Regulation (Reg (EU) 2024/1624) and per-member-state transposition of the sixth AML Directive (6AMLD), could in principle reshape how a national authority such as Austria&#x27;s FMA, which already holds a unified AML/CFT and sanctions mandate domestically under the Sanktionengesetz 2024, interacts with an EU-level supervisory layer for firms with cross-border exposure. This is architecture-over-incident illustration of a structural mechanism, not a forecast of any specific Austrian outcome and not an observed development this cycle.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker Status Note

T1 · Russian Sanctions-Evasion Architecture stable

T2 · EU AML Package / AMLA stable AT bound to AMLR by direct application as EU-27 member; no transposition variance found this cycle.

T3 · FATF Grey List stable AT is not grey-listed; no change identified.

T4 · Beneficial-Ownership Register Status stable WiEReG&#x27;s 2025 nominee-reporting amendment continues to be actively applied; stricter annual-verification practice reported.

T5 · Crypto & Digital-Asset Integrity stable No new AT-specific crypto-AML enforcement within this window; prior FMA fine (summer 2026) predates window.

T6 · Sanctions Regime Divergence stable

Registers

### Enforcement actions

- 23 Jan 2025

- 15 Jul 2025

- 10 Dec 2025

- 2 Jul 2026

- FMA MiCA transition milestone: only 4 of 13 grandfathered CASPs retained authorization by the 31 December 2025 transition deadline (regulatory transition milestone rather than a discrete enforcement action). 31 Dec 2025

- 14 Aug 2026

- 5 May 2026

- 1 May 2026

- 14 Aug 2026

- 18 Aug 2026

- Austrian anti-corruption prosecutors arrested Rene Benko on suspicion of insolvency fraud tied to the EUR23 billion collapse of his Signa property and retail empire, citing risk of collusion and obstruction. 23 Jan 2025

- Benko was formally charged with insolvency fraud after the collapse of his EUR23 billion Signa property empire, accused of funneling assets away from creditors. 15 Jul 2025

- Austrian judges found Benko guilty in a second set of insolvency-fraud charges relating to concealment of luxury watches from creditors, while clearing him of hiding other assets. 10 Dec 2025

- Austria&#x27;s Supreme Court rejected Benko&#x27;s attempt to annul an earlier insolvency-fraud verdict, finalizing a two-year jail sentence — the first criminal case to reach a final verdict following one of Europe&#x27;s largest recent corporate insolvencies. 2 Jul 2026

- The FMA enforced the end of the MiCA grandfathering transition period, requiring all existing CASPs to obtain full MiCA authorization or cease regulated services; only 4 of 13 previously operating CASPs retained authorization. 31 Dec 2025

### Sanctions changes

- 23 Oct 2025

- 1 Aug 2025

- 1 Aug 2025

- 13 May 2026

- The EU adopted its 19th package of Russia sanctions, listing 69 additional individuals/entities and targeting shadow-fleet vessels, the ruble-backed A7A5 stablecoin, third-country banks and Lukoil&#x27;s shadow-fleet enabler Litasco Middle East DMCC — measures with direct relevance to Austrian-headquartered financial institutions&#x27; Russia-linked exposure. 23 Oct 2025

- Austria delayed EU consensus on the 19th sanctions package, seeking to condition its support on unfreezing Deripaska-affiliated Rasperia Trading&#x27;s Strabag stake so that Raiffeisen Bank International could be compensated for a Russian court-ordered payment — a national divergence from collective EU sanctions posture driven by a domestic banking interest. 8 Oct 2025

- OFAC and OFSI designated entities tied to the Russian ruble-backed A7A5 token, its affiliated exchange Grinex (successor to the sanctioned Garantex), and Kyrgyzstani issuer Old Vector, part of a coordinated Western effort against crypto-based sanctions evasion infrastructure with cross-border relevance to EU member-state exposure including Austria&#x27;s MiCA-regulated CASP sector. 1 Aug 2025

### Regulatory horizon (register)

- Austria WiEReG BO-register enhancement deadline (6AMLD)

- AMLR full direct applicability

- Austria WiEReG BO-register enhancement deadline (6AMLD)

- FATF Key Recommended Actions (3-year roadmap post-2026 MER)

- 6AMLD full transposition incl. BO-register access rules

- FATF enhanced follow-up reporting for Austria

- AT beneficial-ownership-register novelle and FMA-independence bill (621 d.B.) advance

- AMLA direct-supervision selection exercise

- AMLR / 6AMLD application date

- Austria&#x27;s FATF enhanced follow-up progress report due

- AMLR (Reg 2024/1624) direct-application date across EU incl. Austria

- 6AMLD transposition deadline for Austria

### Active schemes

- [CRITICAL] Raiffeisen Bank International Russia exposure and wind-down friction

- [HIGH] Rasperia/Deripaska-Strabag sanctions circumvention and Austrian carve-out lobbying

- MiCA transition gap exposes unlicensed CASP residue

- [HIGH] Privatstiftung foundation vehicles shielding insolvent-estate assets

- ISKP crypto-enabled cell financing touching Austrian territory

Sources

- [Regulation (EU) 2024/1157](https://www.niassembly.gov.uk/assembly-business/committees/2022-2027/windsor-framework-democratic-scrutiny-committee/eu-acts/published-eu-acts/regulation-eu-20241157/)

- [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-austria-2026.html)

- [IMF](https://www.elibrary.imf.org/view/journals/002/2026/091/002.2026.issue-091-en.pdf)

- [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html)

- [AML Intelligence](https://www.amlintelligence.com/2026/04/news-fatf-warns-austria-is-falling-short-in-money-laundering-investigations-and-prosecutions/)

- [Mondaq / Kinstellar](https://www.mondaq.com/austria/financial-services/1799420/austria-centralises-financial-sanctions-oversight-fma-assumes-new-powers-in-2026)

- [FMA Österreich](https://www.fma.gv.at/en/austria-clean-financial-centre-fma-to-assume-new-duties-in-the-monitoring-of-international-financial-sanctions/)

- [Brussels Signal](https://brusselssignal.eu/2026/08/austria-dismantles-international-network-supplying-russian-arms-industry-in-breach-of-eu-sanctions/)

- [Duane Morris - European Sanctions Enforcement](https://blogs.duanemorris.com/europeansanctionsenforcement/2026/08/11/austria-suspected-exports-of-military-manufacturing-equipment-lead-to-raids-and-arrest/)

- [Reuters (via Internazionale)](https://www.internazionale.it/ultime-notizie-reuters/2026/08/10/austria-breaks-up-sanctions-evasion-scheme-supplying-russian-arms-industry)

- [Austrian Parliament](https://www.parlament.gv.at/gegenstand/XXVII/ME/353)

- [PFR Rechtsanwälte](https://pfr.at/en/news-en/money-laundering-compliance-en/fatf-audit-adjustment-act-and-fm-gwg-adjustment-act-%E2%80%93-what-is-changing)

- [Open Ownership](https://www.openownership.org/en/map/country/austria/)

- [Cryptonomist](https://en.cryptonomist.ch/2026/08/17/bitpanda-mica-fine-austria/)

- [crypto.news](https://crypto.news/bitpanda-fined-e70000-by-austrian-regulator-over-mica-breaches/)

- [Cambodianess](https://cambodianess.com/article/cambodia-removed-from-the-fatfs-grey-list)

- [FATF](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html)

- [https://www.fma.gv.at/en/from-1-january-2026-the-fma-is-the-new-supervisory-authority-for-monitoring-and-imposing-financial-sanctions/](https://www.fma.gv.at/en/from-1-january-2026-the-fma-is-the-new-supervisory-authority-for-monitoring-and-imposing-financial-sanctions/)

- [https://www.fma.gv.at/en/announcement-fma-imposes-sanction-upon-sparkasse-oberosterreich-bank-ag-for-breach-of-due-diligence-obligations-for-the-prevention-of-money-laundering-and-terrorist-financing/](https://www.fma.gv.at/en/announcement-fma-imposes-sanction-upon-sparkasse-oberosterreich-bank-ag-for-breach-of-due-diligence-obligations-for-the-prevention-of-money-laundering-and-terrorist-financing/)

- [https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-austria-2026.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-austria-2026.html)

- [https://www.elibrary.imf.org/view/journals/002/2026/091/002.2026.issue-091-en.pdf](https://www.elibrary.imf.org/view/journals/002/2026/091/002.2026.issue-091-en.pdf)

- [https://www.kinstellar.com/news-and-insights/detail/4487/austria-centralises-financial-sanctions-oversight-fma-assumes-new-powers-in-2026](https://www.kinstellar.com/news-and-insights/detail/4487/austria-centralises-financial-sanctions-oversight-fma-assumes-new-powers-in-2026)

- [IMF](https://www.imf.org/-/media/files/publications/cr/2026/english/1autea2026001-source-pdf.pdf)

- [FMA](https://www.fma.gv.at/wp-content/plugins/dw-fma/download.php?d=3612)

- [eucrim (Max Planck Institute EU criminal law network)](https://eucrim.eu/news/new-anti-money-laundering-directive-amld-6/)

- [Kinstellar](https://www.kinstellar.com/news-and-insights/detail/4487/austria-centralises-financial-sanctions-oversight-fma-assumes-new-powers-in-2026)

- [Global Defense Corp](https://www.globaldefensecorp.com/2026/08/30/austria-created-eu-sanctions-evasion-schemes-to-supply-rocket-engine-components-to-russia/)

- [ESMA](https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica)

- [Austrian Parliament](https://www.parlament.gv.at/aktuelles/pk/jahr_2026/pk0861)

- [OTS/Austrian Parliamentary Correspondence](https://www.ots.at/presseaussendung/OTS_20260929_OTS0137/finanzausschuss-fuer-neue-regeln-zu-fma-und-registern-wirtschaftlicher-eigentuemer)

- [FMA Österreich](https://www.fma.gv.at/querschnittsthemen/fmafinanzsanktionen/)

- [Börsianer.at](https://www.boersianer.at/artikel/hohe-strafe-fma-greift-bei-kryptos-durch)

- [Austrian Financial Market Authority (FMA)](https://www.fma.gv.at/en/fma-tasks/)

- [Austrian Parliament](https://www.parlament.gv.at/aktuelles/pk/jahr_2024/pk1042)

- [aiaml.com](https://aiaml.com/resources/updates/aml-enforcement-europe-summer-2026)

- [Schoenherr (law firm)](https://www.schoenherr.eu/content/austria-amendment-to-the-austrian-beneficial-owners-register-act-reporting-obligations-for-nominee-agreements)

- [The Block](https://www.theblock.co/news/regulation/2026-08-17-austria-mica-penalty-bitpanda-411960)

- [https://www.fma.gv.at/en/](https://www.fma.gv.at/en/)

- [https://www.fma.gv.at/en/cross-sectoral-topics/financial-sanctions/](https://www.fma.gv.at/en/cross-sectoral-topics/financial-sanctions/)

- [https://www.fma.gv.at/die-fma-warnt-vor-angeboten-von-coinmindz/](https://www.fma.gv.at/die-fma-warnt-vor-angeboten-von-coinmindz/)

- [https://www.fma.gv.at/](https://www.fma.gv.at/)

- [https://www.esma.europa.eu/sites/default/files/2026-10/ESMA43-502934634-2902_Report_on_Sanctions_and_measures_imposed_in_Member_States_in_2025.pdf](https://www.esma.europa.eu/sites/default/files/2026-10/ESMA43-502934634-2902_Report_on_Sanctions_and_measures_imposed_in_Member_States_in_2025.pdf)

- [https://www.fma.gv.at/konzessionsaenderung-durch-verschmelzung-der-raiffeisenbank-mittleres-lavanttal-egen-mit-der-raiffeisenbank-eberndorf-registrierte-genossenschaft-mit-beschraenkter-haftung-und-unteres-lavanttal-egen/](https://www.fma.gv.at/konzessionsaenderung-durch-verschmelzung-der-raiffeisenbank-mittleres-lavanttal-egen-mit-der-raiffeisenbank-eberndorf-registrierte-genossenschaft-mit-beschraenkter-haftung-und-unteres-lavanttal-egen/)

- [Bundesministerium für Finanzen](https://www.bmf.gv.at/dam/jcr:20cd7a6a-93d4-4942-a0fc-972e248b92ca/BORA%20EN.pdf)

- [Schoenherr](https://www.schoenherr.eu/content/austria-amendment-to-the-austrian-beneficial-owners-register-act-reporting-obligations-for-nominee-agreements)

- [VLO Law Firm](https://vlolawfirm.com/legal-updates/austria-2026-q3-regulatory-update)

- [AIAML](https://aiaml.com/resources/updates/aml-enforcement-europe-summer-2026)

- [Mutual Evaluation of Austria](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofaustria.html)

- [Austria](https://www.fatf-gafi.org/en/countries/detail/Austria.html)

- [Austria&#x27;s measures to counter money laundering, terrorist financing and proliferation financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-austria-2026.html)

- [Australia&#x27;s progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Australia-fur-2024.html)

- [Mutual Evaluation Report of Austria](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER%20Austria%20full.pdf.coredownload.pdf)

- [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html)

- [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html)

- [Countries / Jurisdictions](http://www.fatf-gafi.org/countries/#Austria)

- [Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html)

- [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html)

- [Austria Stalls Russia Sanctions Over Raiffeisen Compensation - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-08/austria-stalls-russia-sanctions-over-raiffeisen-compensation)

- [Russian Harmful Foreign Activities Sanctions](https://ofac.treasury.gov/faqs/topic/6626)

- [FinCEN Provides Financial Institutions with Red Flags on Potential Russian Sanctions Evasion Attempts | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-provides-financial-institutions-red-flags-potential-russian-sanctions)

- [Crypto Sanctions: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-sanctions-2026/)

- [D Updated Guidance for Foreign Financial Institutions on OFAC Sanctions](https://ofac.treasury.gov/media/932436/download)

- [Financial Action Task Force Suspends the Membership of the Russian Federation, and Identifies Jurisdictions with Anti-Money Laundering and Combating the Financing of Terrorism and Counter-Proliferation Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-suspends-membership-russian-federation-and)

- [Additional Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/other-ofac-sanctions-lists)

- [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf)

- [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information)

- [U.S. DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/933941/download?inline=)

- [Raiffeisen Bank Under Fire: Austrian Activists Demand Bank Cut Ties with Russia | OCCRP](https://www.occrp.org/en/news/activists-protest-raiffeisen-bank-international-shareholders-meeting-urge-it-to-exit-russia)

- [Raiffeisen Books Provision on €2 Billion Russia Court Order](https://www.bloomberg.com/news/articles/2025-01-20/raiffeisen-books-provision-after-2-billion-russian-court-order)

- [Russia Rejects Raiffeisen Appeal on €2 Billion Court Order - Bloomberg](https://www.bloomberg.com/news/articles/2025-04-24/russia-rejects-raiffeisen-appeal-against-2-billion-court-order)

- [Russia Unit of Austria’s Raiffeisen Bank Has Clients Supplying Putin’s Military - Bloomberg](https://www.bloomberg.com/news/articles/2025-02-03/russia-unit-of-austria-s-raiffeisen-bank-has-clients-supplying-putin-s-military)

- [Raiffeisen Scraps Russia Plan After Regulatory Scrutiny](https://www.bloomberg.com/news/articles/2024-05-08/raiffeisen-scraps-russia-share-plan-after-regulatory-scrutiny)

- [US Sanctions Parties Involved in Raiffeisen’s Axed Russian Deal - Bloomberg](https://www.bloomberg.com/news/articles/2024-05-14/us-sanctions-parties-involved-in-raiffeisen-s-axed-russian-deal)

- [Raiffeisen’s Stalling Russia Strategy Gets ECB Reality Check - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-18/raiffeisen-expects-ecb-will-ask-for-significant-russia-wind-down)

- [Russia-Ukraine Tensions Prompt Austria’s Raiffeisen Bank to Set Aside Funds - Bloomberg](https://www.bloomberg.com/news/articles/2022-02-02/russia-tensions-prompt-austrian-bank-to-stash-funds-for-fallout)

- [Raiffeisen Tumbles as US Visit Highlights Sanctions Tightrope - Bloomberg](https://www.bloomberg.com/news/articles/2024-03-11/raiffeisen-tumbles-as-us-visit-highlights-sanctions-tightrope)

- [Questionnaire on Beneficial Ownership Information Contributions by Austria](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2022-November-7-11/Austria_Responses_to_Questionnaire_on_BOT_Regimes_EN.pdf)

- [Austrian Answers to Questionnaire on Beneficial Ownership Information](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2022-November-7-11/contributions_to_CAC-COSP-WG.2-2022-CRP.1/AUSTRIA_EN.pdf)

- [Beneficial Ownership Registers Interconnection System](https://webgate.ec.europa.eu/e-justice/searchBoris.do)

- [Patchy progress in beneficial ownership registers in the EU | Global Witness](https://globalwitness.org/en/campaigns/corruption-and-money-laundering/patchy-progress-in-setting-up-beneficial-ownership-registers-in-the-eu/)

- [Mutual Evaluation of Austria](https://www.fatf-gafi.org/en/documents/documents/mutualevaluationofaustria.html)

- [European e-Justice Portal - Business registers in EU countries](https://webgate.ec.europa.eu/e-justice/contentPresentation?init=true&member=1&idCountry=at&AUSTRIA=&idTaxonomy=106&isJSOffEnabled=1)

- [Directory of Open-Source Registries: Austria](https://globenetwork.unodc.org/globenetwork/en/directory-of-open-source-registries/austria.html)

- [BOI E-FILING](https://boiefiling.fincen.gov/)

- [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/)

- [10802/26 ADD 1 JAI.2 EN Council of the European Union Brussels, 18 June 2026](https://data.consilium.europa.eu/doc/document/ST-10802-2026-ADD-1/en/pdf)

- [THEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY AUSTRIA](https://www.unodc.org/documents/corruption/WG-Prevention/Art_14_Prevention_of_money-laundering/Austria.pdf)

- [Mutual Evaluation of Austria](https://www.fatf-gafi.org/en/countries/a-c/austria/documents/mutualevaluationofaustria.html)

- [Austria’s progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-austria-2018.html)

- [Austria&#x27;s measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-austria-2016.html)

- [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer/FUR%20Austria.pdf)

- [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26)

- [10802/26 ADD 2 JAI.2 EN Council of the European Union Brussels, 18 June 2026](https://data.consilium.europa.eu/doc/document/ST-10802-2026-ADD-2/en/pdf)

- [Timeline: EU action against money laundering and terrorist financing - Consilium](https://www.consilium.europa.eu/en/policies/fight-against-terrorist-financing/timeline/)

- [Anti-money laundering and countering the financing of terrorism at EU level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en)

- [Anti-money laundering and countering the financing of terrorism legislative package - Finance](https://ec.europa.eu/info/publications/210720-anti-money-laundering-countering-financing-terrorism_en)

- [Anti-money laundering directive V (AMLD V) - transposition status | European Commission](https://ec.europa.eu/info/publications/anti-money-laundering-directive-5-transposition-status_en)

- [Anti-Money Laundering: Commission decides to refer Austria, Belgium and the Netherlands to the Court of Justice of the EU for failing to fully implement EU anti-money laundering rules](https://ec.europa.eu/commission/presscorner/detail/en/ip_20_1228)

- [Fight against money laundering and terrorist financing - Consilium](https://www.consilium.europa.eu/en/policies/fight-against-terrorist-financing/)

- [NIS2 Directive implementation in Austria | Shaping Europe’s digital future](https://digital-strategy.ec.europa.eu/en/policies/nis2-directive-austria)

- [Signa Founder Benko Found Guilty of Hiding Watches in Fraud - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-10/signa-founder-benko-found-guilty-of-insolvency-fraud-standard)

- [Signa’s Benko Charged in Austria After €23 Billion Bankruptcy - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-15/signa-s-benko-charged-in-austria-after-23-billion-bankruptcy)

- [Rene Benko Gets Two-Year Sentence After Insolvency Fraud Verdict in Austria - Bloomberg](https://www.bloomberg.com/news/articles/2026-07-02/ex-tycoon-benko-handed-jail-sentence-for-insolvency-fraud)

- [Oberstes Gericht bestätigt Haftstrafe gegen Signa-Gründer Benko - Bloomberg](https://www.bloomberg.com/news/articles/2026-07-02/oberstes-gericht-bestatigt-haftstrafe-gegen-signa-grunder-benko)

- [Arrest in Austria Marks End of Era for European Property Moguls - Bloomberg](https://www.bloomberg.com/news/newsletters/2025-01-25/arrest-in-austria-marks-end-of-era-for-european-property-moguls)

- [Signa’s Rene Benko to Remain in Pre-Trial Detention Amid Fraud Investigation - Bloomberg](https://www.bloomberg.com/news/articles/2025-01-24/signa-s-benko-to-remain-in-detention-amid-fraud-investigation)

- [Austria Issues Arrest Warrant for Signa Founder Rene Benko](https://www.bloomberg.com/news/articles/2025-01-23/austria-issues-arrest-warrant-for-signa-founder-rene-benko)

- [Signa Founder Benko Files for Personal Insolvency in Austria - Bloomberg](https://www.bloomberg.com/news/articles/2024-03-07/signa-founder-benko-files-for-personal-insolvency-in-austria)

- [Mubadala’s €1 Billion Award Pushes Trust Linked to Signa’s Benko Into Insolvency](https://www.bloomberg.com/news/articles/2026-03-11/mubadala-s-1-billion-award-pushes-trust-linked-to-signa-s-benko-into-insolvency)

- [Austria Probing Sale by Benko’s Signa That Led to Insolvency - Bloomberg](https://www.bloomberg.com/news/articles/2023-06-12/austria-probing-sale-by-benko-s-signa-that-led-to-insolvency)

- [19th package of sanctions against Russia - consilium.europa.eu](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/pdf/)

- [EU Effort to Toughen Russia Sanctions Stalls as Austria Digs In - Bloomberg](https://www.bloomberg.com/news/newsletters/2025-10-09/eu-effort-to-toughen-russia-sanctions-stalls-as-austria-digs-in)

- [Raiffeisen Says Lifting Sanctions on Rasperia in EU’s Interest - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-08/raiffeisen-says-lifting-sanctions-on-rasperia-in-eu-s-interest)

- [EU adopts 19th package of sanctions against Russia - Finance](https://finance.ec.europa.eu/news/eu-adopts-19th-package-sanctions-against-russia-2025-10-23_en)

- [Billionaire Deripaska Challenges Scope of EU Sanctions on Russia - Bloomberg](https://www.bloomberg.com/news/articles/2023-02-14/billionaire-deripaska-challenges-scope-of-eu-sanctions-on-russia)

- [Statement by President von der Leyen on the 19th package of sanctions against Russia](https://ec.europa.eu/commission/presscorner/detail/en/statement_25_2138)

- [19th package of sanctions against Russia: EU targets Russian energy, third-country banks and crypto providers - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/)

- [Timeline - EU sanctions against Russia - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-sanctions-against-russia/)

- [Russia&#x27;s war of aggression against Ukraine: EU lists two ...](https://www.consilium.europa.eu/en/press/press-releases/2024/06/28/russia-s-war-of-aggression-against-ukraine-eu-lists-two-individuals-and-four-entities-for-circumventing-eu-sanctions-and-materially-supporting-the-russian-government/pdf/)

- [FATF report highlights evolving terrorist financing risks and warns of gaps in global understanding of the threats](https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html)

- [Comprehensive Update on Terrorist Financing Risks FATF REPORT July 2025](https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Comprehensive-Update-on-Terrorist-Financing-Risks-2025.pdf.coredownload.inline.pdf)

- [Category deep-dive: Use of crypto in terrorist financing expanded in 2024 | TRM Labs](https://www.trmlabs.com/resources/blog/category-deep-dive-use-of-crypto-in-terrorist-financing-expanded-in-2024)

- [FinCEN Advisory, FIN-2025-A001, April 1, 2025](https://www.fincen.gov/system/files/advisory/2025-04-01/FinCEN-Advisory-ISIS-508C.pdf)

- [CTED Trends Tracker Evolving Trends in the Financing of Foreign Terrorist](https://www.un.org/securitycouncil/ctc/sites/www.un.org.securitycouncil.ctc/files/cted_trends_tracker_evolving_trends_in_the_financing_of_foreign_terrorist_fighters_activity_2014_-_2024.pdf)

- [Muslim Brotherhood suspect and Saudi billionaire linked to same offshore companies, Austrian report says - ICIJ](https://www.icij.org/investigations/paradise-papers/muslim-brotherhood-suspect-and-saudi-billionaire-linked-to-same-offshore-companies-austrian-report-says/)

- [Assessing Terrorism Financing On-chain is Crucial and Complex - Chainalysis](https://www.chainalysis.com/blog/assessing-terrorism-financing-on-chain/)

- [Cryptocurrency and Terrorism Financing: Correcting the Record](https://www.chainalysis.com/blog/cryptocurrency-terrorism-financing-accuracy-check/)

- [Australia&#x27;s Crypto Crossroads - Chainalysis](https://www.chainalysis.com/blog/australia-crypto-crossroads-2026/)

- [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html)

- [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp)

- [What Is a VASP? Virtual Asset Service Provider - Chainalysis](https://www.chainalysis.com/glossary/virtual-asset-service-provider/)

- [Austrian Financial Market Authority (FMA) | EU Digital Finance Platform](https://digital-finance-platform.ec.europa.eu/cross-border-services/cross-border-testing/participants/austrian-financial-market-authority-fma)

- [FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html)

- [FATF Issues Comprehensive Guidance on Virtual Asset Recovery](https://www.chainalysis.com/blog/fatf-guidance-virtual-asset-recovery-law-enforcement-november-2025/)

- [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/)

- [Quick guide on assessing the Money Laundering risks of virtual assets (VA) and virtual asset service providers (VASP)](https://www.fatf-gafi.org/en/publications/Methodsandtrends/quick-guide-on-assessing-ML-risks-of-VA-and-VASPs.html)

- [Anti-money laundering and countering the financing of terrorism legislative package - Finance](https://finance.ec.europa.eu/publications/anti-money-laundering-and-countering-financing-terrorism-legislative-package_en)

- [Register or update your money laundering supervision with HMRC - GOV.UK](https://www.gov.uk/guidance/register-or-renew-your-money-laundering-supervision-with-hmrc)

- [MDR - extension of the transition period - European Union](https://health.ec.europa.eu/document/download/48035948-beb1-47b3-8be2-8c500e59c24b_en?filename=md_20240926_imdrf2023_24th-session_day2_pres03.pdf)

- [Anti-money laundering: Council and Parliament strike deal on stricter rules - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/01/18/anti-money-laundering-council-and-parliament-strike-deal-on-stricter-rules/)

- [Anti-money laundering: Council adopts package of rules - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/05/30/anti-money-laundering-council-adopts-package-of-rules/)

- [Overview of financial services legislation - Finance - European Commission](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/overview-financial-services-legislation_en)

- [Timeline: EU action against money laundering and terrorist financing - Consilium](https://www.consilium.europa.eu/en/policies/fight-against-terrorism/fight-against-terrorist-financing/timeline/)

- [Regulation (EU) 2024/1157](https://www.niassembly.gov.uk/assembly-business/committees/2022-2027/windsor-framework-democratic-scrutiny-committee/eu-acts/published-eu-acts/regulation-eu-20241157/)

- [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-austria-2026.html)

- [Federal Ministry of Finance Austria](https://www.bmf.gv.at/dam/jcr:19c18523-a864-4e9b-97ef-bc30b4d705ca/National%20Risk%20Assessment%202021.pdf)

- [OCCRP](https://www.occrp.org/en/news/activists-protest-raiffeisen-bank-international-shareholders-meeting-urge-it-to-exit-russia)

- [Bloomberg](https://www.bloomberg.com/news/articles/2025-10-08/austria-stalls-russia-sanctions-over-raiffeisen-compensation)

- [Council of the European Union](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/pdf/)

- [Global Witness](https://globalwitness.org/en/campaigns/corruption-and-money-laundering/patchy-progress-in-setting-up-beneficial-ownership-registers-in-the-eu/)

- [TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26)

- [European Commission (DG FISMA)](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en)

- [UNODC (hosting Austria&#x27;s national submission)](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2022-November-7-11/contributions_to_CAC-COSP-WG.2-2022-CRP.1/AUSTRIA_EN.pdf)

- [Bloomberg](https://www.bloomberg.com/news/articles/2026-07-02/ex-tycoon-benko-handed-jail-sentence-for-insolvency-fraud)

Coverage gaps

fim-int-2026-07-07-G001: Independent, granular data on the A… fim-int-2026-07-07-G001: Independent, granular data on the A-FIU&#x27;s budgetary allocation and staffing levels would substantiate the FATF-flagged resourcing deficiency beyond narrative summary. [resolved]

fim-int-2026-07-07-G002: Case-level DNFBP supervisory enforc… fim-int-2026-07-07-G002: Case-level DNFBP supervisory enforcement records (beyond casinos, lawyers, notaries) would allow assessment of the true scale of the fragmented-supervision gap. [resolved]

fim-int-2026-07-07-G003: Primary-source verification (e.g. a… fim-int-2026-07-07-G003: Primary-source verification (e.g. a regulatory filing, court record, or corroborating T1-T2 report) of the specific USD10 billion RBI pre-invasion cash-shipment figure is needed; the cited OCCRP source does not contain this quantum per challenge review. [resolved]

fim-int-2026-07-07-G004: Direct FMA crypto-asset service pro… fim-int-2026-07-07-G004: Direct FMA crypto-asset service provider register data would reconcile the conflicting MiCA CASP authorisation counts (TRM Labs reports 4 of 13; Chambers reports 8 licences granted). [resolved]

fim-int-2026-07-07-G005: An independent data-quality audit o… fim-int-2026-07-07-G005: An independent data-quality audit of WiEReG beneficial-ownership register content (beyond FATF&#x27;s own assessment) would corroborate or qualify the register&#x27;s praised effectiveness. [resolved]

fim-int-2026-08-17-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-08-17-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No AT-specific D3 enabler-jurisdiction development located this cycle; MER&#x27;s structural transit-point characterisation is carried forward rather than newly evidenced. [resolved]

fim-int-2026-08-17-G002: No Mexico or Colombia (Tier D) sign… fim-int-2026-08-17-G002: No Mexico or Colombia (Tier D) signal located this cycle; logged as a genuine sourcing gap rather than an asserted no-material-change. [resolved]

fim-int-2026-08-17-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-08-17-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): No T1 FMA press release located for the Bitpanda MiCA penalty; sourcing relies on two independent T3 outlets. [resolved]

fim-int-2026-09-21-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-21-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No AT-specific enabler-jurisdiction (professional facilitator) evidence was located within the pooled search budget for this cycle. [resolved]

fim-int-2026-09-21-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-21-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D4&#x27;}): No AT-specific conflict-finance evidence was located within the pooled search budget for this cycle. [resolved]

fim-int-2026-09-21-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-21-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D6&#x27;}): No AT-specific compliance-technology/RegTech guidance was located within the pooled search budget for this cycle. [resolved]

fim-int-2026-09-21-G004: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-09-21-G004: Tier D jurisdictions (KH, LA, MX, CO) were out of scope for this AT-bound single-jurisdiction pass; not asserted as null findings. [resolved]

fim-int-2026-09-28-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No AT-specific D3 (Enabler Jurisdictions) finding was located this cycle; the IMF&#x27;s own flag on Treuhand structures as a common feature of the Austrian economy warrants revisiting. [resolved]

fim-int-2026-09-28-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D4&#x27;}): No AT-specific D4 (Conflict Finance) finding was located this cycle. [resolved]

fim-int-2026-09-28-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D6&#x27;}): No AT-specific D6 (Compliance Technology and Active Defence) development was located this cycle. [resolved]

fim-int-2026-10-04-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No AT-specific D3 (Enabler Jurisdictions) finding this cycle; general search did not reach this domain. [resolved]

fim-int-2026-10-04-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D4&#x27;}): No AT-specific D4 (Conflict Finance) finding this cycle; general search did not reach this domain. [resolved]

fim-int-2026-10-04-G003: Tier-D watch (KH/LA/MX/CO) was not … fim-int-2026-10-04-G003: Tier-D watch (KH/LA/MX/CO) was not performed this cycle; the AT-only binding directive for this run precluded cross-jurisdiction checks. [resolved]

fim-int-2026-10-04-G004 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G004 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): Whether any AT-headquartered or AT-branch financial group appears on AMLA&#x27;s provisional eligible-entity list (due end-Sept 2026) was not confirmed this cycle. [resolved]

fim-int-2026-10-11-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-11-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): No FMA primary press release confirming the Kurant GmbH penal order as final; relies on a single T3 secondary source. [resolved]

fim-int-2026-10-11-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-11-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): No national 6AMLD transposition instrument or AMLA direct-supervision designation for Austria located this cycle. [resolved]

fim-int-2026-10-11-G003: No Tier D (Cambodia/Laos/Mexico/Col… fim-int-2026-10-11-G003: No Tier D (Cambodia/Laos/Mexico/Colombia) Austria-linked nexus sweep separately conducted for AT given pooled search budget constraints. [resolved]

fim-int-2026-10-18-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-18-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D4&#x27;}): Conflict-finance, deeper enabler-jurisdiction material beyond the Coinmindz warning, and compliance-technology/RegTech developments specific to Austria were not surfaced this cycle. [resolved]

fim-int-2026-10-18-G002: Tier D jurisdiction coverage (KH, L… fim-int-2026-10-18-G002: Tier D jurisdiction coverage (KH, LA, MX, CO) was not conducted in this AT-bound per-jurisdiction dispatch, which is expected given the single-jurisdiction scope. [resolved]

fim-int-2026-10-25-G001: No FMA or BMF announcement dated in… fim-int-2026-10-25-G001: No FMA or BMF announcement dated inside this cycle&#x27;s window was found for D1 (sanctions), D2 (beneficial ownership), D3 (enabler jurisdictions), D4 (conflict finance) or D6 (compliance technology) specific to AT. [open]

fim-int-2026-11-01-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-11-01-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D1&#x27;}): Five of eight domain modules (D1, D3, D4, D5, D6) had thin or no AT-specific coverage this cycle; T1 primary sources were not retrieved for several standing-tracker items. [open]

fim-int-2026-11-01-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-11-01-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): WiEReG annual-confirmation cadence and four-week deadline mechanics rest on T3 law-firm corroboration, not directly quoted from the T1 BMF instrument this cycle. [open]

FIM-GAP-001 (D3): Austria&#x27;s Financial Intelligence Unit (A-F… FIM-GAP-001 (D3): Austria&#x27;s Financial Intelligence Unit (A-FIU) suffers from insufficient resources and limited budgetary/recruitment independence, focusing too narrowly on predicate offences rather than complex or cross-border money-laundering cases, per FATF&#x27;s April 2026 MER.

FIM-GAP-002 (D3): Except for casino supervision and, to some… FIM-GAP-002 (D3): Except for casino supervision and, to some extent, lawyers and notaries, Austrian DNFBP (designated non-financial businesses and professions) supervision suffers from major shortcomings including fragmentation, resource shortages, and few remedial actions.

FIM-GAP-003 (D1): Austria leveraged its EU Council veto to d… FIM-GAP-003 (D1): Austria leveraged its EU Council veto to delay the bloc&#x27;s 19th Russia sanctions package, conditioning support on unfreezing Deripaska-linked Rasperia assets to compensate Raiffeisen Bank International — a national financial interest overriding collective sanctions solidarity.

FIM-GAP-004 (D2): Public-facing access to Austria&#x27;s WiEReG b… FIM-GAP-004 (D2): Public-facing access to Austria&#x27;s WiEReG beneficial-ownership register requires a per-search fee (approx. EUR4 per statement), which Global Witness identifies as a paywall limiting practical accessibility despite nominal public availability; independent open-source verification of BO data quality beyond FATF&#x27;s own praise is comparatively thin.

## Evidence

#### Confidence-tiered claims

Finanzausschuss voted 29 September 2026 (ÖVP, SPÖ, NEOS, FPÖ in favour) to advance a novelle harmonising and strengthening the legal framework for Austria&#x27;s register of beneficial owners to the Nationalrat. [[Source 1]](#sec-sources)

Probable · 1 source

The Finanzausschuss forwarded a bill transposing CRD VI (Directive 2013/36/EU as amended by (EU) 2024/1619), introducing mandatory cooling-off periods, annual interest declarations, a 14-year FMA board-tenure cap, and new credit-institution notification duties for &#x27;prudentially relevant&#x27; transactions subject to FMA AML/CFT assessment. [[Source 1]](#sec-sources)

Probable · 1 source

FMA published its first legally-final MiCAR enforcement decision on 14 August 2026, fining Bitpanda GmbH EUR 70,000 for late whitepaper notification, premature marketing communication and missing mandatory disclosures. [[Source 1]](#sec-sources)

Probable · 1 source

Austria&#x27;s FATF Mutual Evaluation Report was adopted at the February 2026 plenary and published 30 April 2026; Austria was found largely-compliant/compliant across most Recommendations and was not placed on the grey list, though FIU operational capacity and asset-confiscation effectiveness were flagged as needing improvement. [[Source 1]](#sec-sources)

Probable · 1 source

FMA consolidated supervision and enforcement of national and EU/UN financial sanctions (incl. Russia, Iran) from the OeNB as of 1 January 2026 under the Sanktionengesetz 2024, now covering payment institutions, e-money institutions and crypto-asset service providers in addition to banks and insurers. [[Source 1]](#sec-sources)

Probable · 1 source

€45,000 by FMA under FM-GwG for deficient written CDD/monitoring procedures [[Source 1]](#sec-sources)

Probable · 1 source

sanctions-compliance supervision from OeNB, effective 1 January 2026, under Sanktionengesetz 2024, scope expanded to insurance, investment firms, AIFMs, EMIs and crypto-asset service providers [[Source 1]](#sec-sources)

Probable · 1 source

Compliant/Largely Compliant on all but one of 40 FATF Recommendations; Key Recommended Actions on FIU/law-enforcement capacity for complex ML investigations and asset confiscation; not on grey list [[Source 1]](#sec-sources)

Probable · 1 source

€70,000 by FMA for MiCA white-paper notification and premature/non-compliant marketing-communication breaches; first published legally-binding MiCA penalty in Austria [[Source 1]](#sec-sources)

Probable · 1 source

key strength of the AML/CFT system per 2026 FATF MER; nominee-agreement reporting amendment effective 1 October 2025 remains latest structural change [[Source 1]](#sec-sources)

Probable · 1 source

Authorised as a crypto-asset service provider under MiCAR by FMA administrative decision dated 13 October 2026, published 14 October 2026, enabling EEA-wide passporting. [[Source 1]](#sec-sources)

Probable · 1 source

FMA published a warning on 6 October 2026 stating Coinmindz (purported Dubai seat) is not authorised to provide licensable securities/investment-advice services in Austria. [[Source 1]](#sec-sources)

Probable · 1 source

Since 1 January 2026 the FMA holds unified competence for AML/CFT and financial-sanctions oversight across all Austrian financial-market participants under the Sanctions Act 2024 (Sanktionengesetz 2024), following transfer of sanctions-monitoring powers from the OeNB. [[Source 1]](#sec-sources)

Probable · 1 source

Austria accounted for approximately 4% of the ~955 administrative sanctions and measures imposed across the EEA in 2025, per ESMA&#x27;s third consolidated report [[Source 1]](#sec-sources)

Probable · 1 source

2025 was the first year administrative sanctions and measures were issued EEA-wide under MiCA [[Source 1]](#sec-sources)

Probable · 1 source

Concession lapsed following merger into Raiffeisenbank Burgenland Mitte eGen, registered in companies register 2026-09-17; FMA notice published 2026-10-21 [[Source 1]](#sec-sources)

Probable · 1 source

FATF MER adopted February 2026, published 30 April 2026; AT placed in enhanced follow-up; clear progress noted on beneficial-ownership transparency, financial-sector supervision and terrorist-financing investigations [[Source 1]](#sec-sources)

Probable · 1 source

As of 1 January 2026, the FMA assumed full responsibility for monitoring and enforcement of international financial sanctions across the Austrian financial sector, pursuant to the Sanktionengesetz 2024 [[Source 1]](#sec-sources)

Probable · 1 source

annual confirmation plus 4-week update deadline [[Source 1]](#sec-sources)

Probable · 1 source

nominee/fiduciary agreement disclosure mandatory from 1 October 2025 [[Source 1]](#sec-sources)

Probable · 1 source

FMA fine for inadequate written AML policies, summer 2026, following an October 2025 €70,000 fine [[Source 1]](#sec-sources)

Probable · 1 source

Companies must confirm beneficial-ownership data at least annually and report ownership-chain changes within four weeks; nominee/fiduciary agreements at the direct-owner level must be disclosed regardless of percentage of interest covered [[Source 1]](#sec-sources)

Probable · 1 source
