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 “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Belgium BE

Domains covered

8 of 8

Sources

166

Role actions

Horizon <90d

Jurisdiction profile

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

Belgium's AML/CFT/CPF regime rests on the AML/CFT Law, CTIF-CFI (FIU), and Twin Peaks supervision (NBB/FSMA).

The FATF's December 2025 mutual evaluation found the system technically largely aligned with FATF standards but effectiveness-deficient, placing Belgium in enhanced follow-up with a three-year Key Recommended Actions roadmap.

Key deficiencies

No authority designated to licence or supervise virtual asset service providers
Very limited use of administrative sanctions by financial supervisors, with near-anonymous publication of decisions
Resource-constrained prosecutions prioritised by asset profitability rather than complexity or risk
Limited detection capacity for hawala/informal value transfer and virtual-asset-based laundering
UBO register access restricted to Belgian citizens/residents with eID or Belgian tax number, undermining public transparency

Recent developments (18m)

FATF adopted Belgium's 5th-round mutual evaluation report (16 Dec 2025), the first assessment under the new time-bound, risk-based methodology alongside Malaysia
Belgian federal court convicted seven members of an ISIS crypto-financing/CBRN-precursor network (9 June 2026)
Belgium became the central diplomatic and legal battleground over ~€258bn in frozen Russian central bank assets held at Euroclear, resisting an EU reparations-loan plan (Oct 2025–2026)
Euroclear eased payment rules for frozen Russian securities following consultation with authorities (March 2026)

Law made at European Economic Area level that applies in Belgium is covered once, on the European Economic Area page. This page covers Belgium’s own layer: implementation, national authorities, national options and local enforcement.

Brief

Lead signal

Lead Signal

Belgium's position in the EU's MiCA crypto-asset authorisation architecture crystallised this period with the close of the regime's transitional window. The Belgian Financial Services and Markets Authority confirmed that, as of the 1 July 2026 expiry of the grandfathering period, no crypto-asset service provider holds a domestic authorisation granted by that regulator, and six previously-operating firms have since been added to its public list of unauthorised providers. This is a structural finding rather than an enforcement one: the mechanism being exercised is a published warning list, not a prosecution or asset freeze, and the absence of any FSMA-authorised domestic CASP population almost a year into the regime's operative phase says something about Belgium's licensing throughput that a single enforcement action would not. A separate commercial register tracking EU-wide CASP status reports a different count for Belgium, which the underlying record does not reconcile against the regulator's own account; the gap between a primary-authority statement and a secondary tracker is itself worth noting rather than resolving by assumption.

Read full brief

Lead Signal

Other Developments

A new eligibility annex inside a familiar instrument. The National Bank of Belgium's periodic anti-money-laundering questionnaire, which obliged entities already complete at regular intervals, gained a seventh annex in a circular dated 16 February 2026: a form addressing eligibility under Article 12 of the Anti-Money Laundering Authority's founding regulation. The addition is reported, not independently verified against the circular text itself, but it reads as Belgium's national supervisor doing preparatory administrative work ahead of the 2027 round in which the EU's new Authority will select which cross-border obliged entities it will supervise directly. That a periodic questionnaire absorbed new content tied to a future EU-level supervisory handover is a small data point, but it belongs to the pattern of national machinery quietly realigning around a central authority before that authority is fully operational.

The baseline AML/CFT architecture holds steady. Belgium's governing AML/CFT statute remains the Act of 18 September 2017, its financial intelligence unit remains the body known as CTIF in French and CFI in Dutch, and since 30 September 2024 that unit has accepted suspicious-transaction declarations exclusively through the goAML platform, with no paper or email channel retained. None of this moved this period; it is recorded here because a reported procedural modernisation, like the exclusive electronic-filing channel, is sometimes mistaken for ongoing change when it is in fact settled practice.

Cross-Monitor Connections

The crypto-authorisation finding sits squarely at the intersection of this monitor's sanctions-and-integrity lens and the payments-infrastructure lens maintained elsewhere: a jurisdiction with zero domestically-authorised crypto-asset service providers, operating under an EU passporting regime that allows foreign-authorised firms to serve its market regardless, is a jurisdiction whose domestic supervisory reach over crypto activity is narrower than its market exposure to crypto activity. That asymmetry is the kind of structural gap that correspondent and payment-infrastructure analysis is built to surface, and it is flagged here for that reason rather than analysed further. The AMLA Article 12 eligibility annex likewise connects outward: the Authority's direct-supervision selection process will eventually touch firms across the bank, payment, and investment-firm sectors that other monitors track on their own structural terms, and Belgium's early paperwork is one data point in a much larger EU-wide realignment.

Outlook

The item most likely to resolve in the near term is the discrepancy between the regulator's own zero-authorisation statement and the commercial tracker's different count; a reconciliation against the European Securities and Markets Authority's own register would settle whether Belgium's domestic CASP population is genuinely empty or whether an authorisation has been granted but not yet reflected in FSMA's public communications. On a longer horizon, the AMLA selection round expected in 2027 will determine which Belgian-domiciled obliged entities move under direct EU-level supervision rather than purely national oversight, and the February 2026 circular's new eligibility annex is best read as the first visible step of Belgium's institutions preparing for that transition rather than as a development complete in itself.

Earlier periodic briefs (5)

18 Oct 2026 · fim-2026-10-18

Lead Signal

Belgium's National Bank publicly named Wise Europe SA under the NBB's tougher 2026 approach to publishing anti-money-laundering enforcement measures, making Wise the first financial-services company identified under this regime. Under Article 93 §2(1) of the AML Law of 18 September 2017, the NBB made public that Wise Europe SA had failed to abide by an earlier order, issued 8 July 2025, requiring compliance with specified provisions by 31 March 2026. The naming itself rests on Article 98/1 of the same Law, which permits the NBB to publicly disclose administrative measures against regulated entities for AML non-compliance, including a failure to remediate within a stated deadline. This is a structural shift in enforcement transparency at the NBB, not an isolated penalty: the architecture for public naming already existed in statute, and this cycle is the first instance of the NBB actually exercising it against a named, supervised payment institution.

Other Developments

Belgium's crypto-asset supervisory posture moved from gap to active enforcement within the same period this cycle covers. FATF's December 2025 mutual evaluation found that, as of its on-site visit, no authority in Belgium had been designated to license or supervise virtual asset service providers, even as the broader AML/CFT/CPF system was assessed as technically largely aligned with the FATF Recommendations. That supervisory gap sat alongside Belgium's domestic MiCA transitional regime for crypto-asset service providers, which expired 1 July 2026; the FSMA responded by adding six unauthorised crypto-asset service providers to its fraudulent-provider warning list between 6 and 10 July 2026. The sequence is notable precisely because it shows the enforcement response arriving after the supervisory-gap finding was made, rather than before it — a FATF-documented absence followed within months by the first concrete enforcement action under the expired transitional window. A prudential-supervision update also moved this cycle. The Law of 22 July 2026 transposes Directive (EU) 2024/1619 (CRD6) into Belgian law, updating the National Bank of Belgium's supervisory powers, its sanctions regime for breaches, third-country branch rules, and ESG risk provisions for credit institutions. This is a general banking-supervision transposition rather than an AML-specific instrument, but it touches the same NBB sanctions architecture now visibly in use against Wise Europe SA.

Cross-Monitor Connections

The FSMA's post-MiCA enforcement action against six unauthorised crypto-asset service providers is tracked in parallel by the crypto monitor, which frames the same facts from a licensing-regime perspective, and by the world-payments monitor, which frames the MiCA transitional-deadline expiry from a stablecoin-and-digital-money infrastructure perspective. Readers should treat these as three lenses on one underlying event set rather than as independent corroboration. The Chift Series A funding round, discussed under Commercial Activity below, is a comparable cross-monitor item: the world-payments monitor tracks the same transaction as a payments-connectivity commercial development.

Outlook

The NBB's willingness to name Wise Europe SA publicly signals that other supervised entities with outstanding remediation deadlines may face similar public disclosure going forward; whether the NBB applies this tool again before the end of 2026 is the immediate item to watch. On the crypto side, the open question FATF's MER left unresolved — whether Belgium designates a specific authority with clear VASP/CASP supervisory competence beyond the FSMA's enforcement-only posture evidenced this cycle — remains unanswered. The CRD6 transposition's practical effect on NBB sanctions practice, including whether it changes the threshold or procedure for public naming under Article 98/1, has not yet been tested against a case.

11 Oct 2026 · fim-2026-10-11

Lead Signal

Belgium's crypto-asset supervisory architecture reached full operability this cycle while its authorised population remained at zero. The Belgian Law of 11 December 2025, implementing MiCAR, has been fully in force since 3 January 2026 and divides competence between the FSMA, which handles CASP authorisation, conduct, and non-stablecoin issuance, and the National Bank of Belgium, which supervises asset-referenced-token and e-money-token issuers. As of FSMA's own mid-2026 communications, no crypto-asset service provider has yet received an FSMA-granted authorisation, and on 6 July 2026, following the 1 July 2026 expiry of the MiCA transitional regime, FSMA added six unauthorised firms to its fraudulent-CASP list. This pairing of a fully operative legal perimeter with a zero-occupant authorised population is itself the architecture-level finding: the enforcement mechanism against unauthorised activity is already active and has already been used, even though the authorisation gate it protects has not yet admitted a single applicant.

Other Developments

FSMA's active-defence tooling continued to scale. FSMA's automated website-blocking system is credited, in the regulator's own 1 October 2026 press release, with preventing 80,000 potential victims of online investment fraud, and the regulator's 'trusted flagger' status has supported faster takedown of fraudulent social-media advertising. On 24 September 2026, FSMA added 51 new fraudulent platforms to its warning list. This is a distinct development from the CASP enforcement action above, operating through a different mechanism, website and platform blocking rather than authorisation-perimeter enforcement, but it sits within the same broader pattern of FSMA building out active-defence capability against unauthorised and fraudulent financial activity.

Belgium's 6AMLD transposition status carries an unresolved internal contradiction. The European Commission's own transposition tracker, last updated 7 August 2026, lists Belgium among Member States with an open infringement procedure for non-communication of national transposition measures for Directive (EU) 2024/1640, the Sixth AML Directive, while simultaneously listing Belgium among states that have communicated full transposition measures for the 10 July 2025 tranche. This is not a minor administrative discrepancy: it means the Commission's own primary tracking instrument cannot currently answer, on its face, whether Belgium's 6AMLD transposition is complete. The contradiction remains unresolved as of the most recent tracker update available within this window.

A named NBB enforcement action against Wise Europe SA illustrates the practical weight of CDD remediation deadlines. On 25 August 2026, the National Bank of Belgium published two named decisions against Wise Europe SA under Articles 98/1 and 93 Section 2(1) of the Belgian AML Law of 18 September 2017, recording customer due-diligence shortcomings under Articles 13 Section 1, 23, 26, 27, and 35 Section 1 of that law. The NBB's decisions record that Wise Europe SA missed a 31 March 2026 remediation deadline, and a new deadline of 31 January 2027 has now been set. This is a secondary-sourced account of a named NBB decision; the NBB's own publication was not independently retrieved within this review window.

Cross-Monitor Connections

The zero-CASP-authorisation finding and the FSMA enforcement actions against unauthorised crypto firms connect directly to the world-payments monitor's coverage of Belgium's stablecoin and digital-money landscape, where the same underlying facts are read through a payments-market-access lens rather than a financial-crime-architecture lens. The Wise Europe SA enforcement action similarly intersects with payment-institution supervision more broadly, given Wise's status as a payment company subject to both AML and payments-conduct oversight.

Outlook

The principal question to track is whether the FSMA grants Belgium's first domestic CASP authorisation, which would resolve the current zero-occupant state of an otherwise fully operative licensing perimeter. The unresolved contradiction in Belgium's 6AMLD transposition status, as recorded by the Commission's own tracker, is also worth monitoring for clarification in a future tracker update. Wise Europe SA's new 31 January 2027 remediation deadline provides a concrete date against which to assess whether the NBB's enforcement action achieves its stated compliance objective.

28 Sep 2026 · fim-2026-09-28

Lead Signal

Belgium's FSMA closed the national MiCA transitional window for crypto-asset service providers on 1 July 2026 with zero authorisations granted under either the pre-MiCA national regime established by the Royal Decree of 8 February 2022 or under MiCA itself. Days later, on 6 July 2026, the FSMA designated six providers -- Aurum Foundation, Bank Bit, Bithf Pro, Dxago, Global Dynamic Trade, and ZeriaFunding -- as operating in Belgium without the required authorisation, marking the first visible national-level enforcement action of the closed MiCA transitional perimeter. This is a structural development: Belgium's CASP sector moved from an unregistered transitional footing directly into a strictly enforced authorisation perimeter with no continuity of previously licensed incumbents, meaning every CASP serving Belgian customers as of this cycle is, on the FSMA's own account, unauthorised.

The significance extends beyond a single enforcement action. A jurisdiction that grants zero authorisations through an entire transitional window, then moves immediately to naming operators as fraudulent, demonstrates both a strict authorisation bar and an active supervisory posture, in contrast to jurisdictions where transitional windows quietly lapse without visible follow-through.

Other Developments

Belgium's AML/CFT architecture remains anchored in the Law of 18 September 2017. This statute designates CTIF-CFI, an independent administrative authority led by a magistrate, as Belgium's financial intelligence unit, with a defined obliged-entity list under Article 5 that already captures providers of exchange services between virtual currencies and fiat currencies established in Belgium. This is a stable, baseline-descriptive architecture unchanged this cycle, but it is the structural backdrop against which the FSMA's crypto enforcement action operates: obliged-entity status for crypto-fiat exchange providers under the 2017 Law sits alongside, and is legally distinct from, the MiCA authorisation requirement enforced by the FSMA.

The EU AML Package advances on its standard EU-27 timetable. The AML Regulation (AMLR, Regulation (EU) 2024/1624) becomes fully applicable on 10 July 2027 without requiring national transposition, being directly applicable across all member states. The sixth AML Directive (6AMLD, Directive (EU) 2024/1640) requires national transposition, with provisions on further development of beneficial-ownership registers due by 10 July 2026 and the bulk of remaining provisions due by 10 July 2027. The Anti-Money Laundering Authority (AMLA, established under Regulation (EU) 2024/1620) becomes operational in mid-2026 but does not begin direct supervision of high-risk obliged entities until January 2028. No Belgium-specific national transposition instrument for the 6AMLD beneficial-ownership register development deadline has been located this cycle, which caps confidence on Belgium's specific compliance status at Probable rather than Confirmed.

Antwerp's diamond sector carries standing structural AML exposure. Industry AML training material describes international corporate structuring and free-trade-zone routing, including routing through jurisdictions such as Dubai, as features that can obscure oversight of diamond-sector transactions. This is characterised as a persistent structural vulnerability rather than a fresh finding this cycle, and no primary regulator or enforcement instrument corroborates it beyond a single industry-training source, so confidence remains capped at Uncertain.

Cross-Monitor Connections

The FSMA's MiCA enforcement action is directly relevant to the crypto monitor, which tracks the same CASP authorisation closure and fraudulent-provider designation as its own D5-equivalent licensing finding. It also connects to the world-payments monitor's W11 AML/CFT domain, since the crypto monitor's stablecoin_regime module and the world-payments monitor's digital-money tracking both rest on the same underlying MiCA authorisation architecture that the FSMA is now actively enforcing. No conflict-finance or sanctions-architecture connections were identified for Belgium this cycle beyond the diamond-sector structural observation, which remains a standing, low-confidence signal rather than an active cross-monitor escalation.

Outlook

Whether the FSMA grants any CASP authorisation following the 1 July 2026 deadline closure will be the key indicator of whether Belgium's crypto sector moves from a zero-authorisation state toward a functioning licensed market, or whether the current enforcement-only posture persists. Separately, confirmation of Belgium's specific national transposition instrument for the 6AMLD beneficial-ownership register development deadline of 10 July 2026 would resolve the current gap between the EU-wide timetable and Belgium's confirmed compliance status. Both developments warrant continued monitoring into the next cycle.

21 Sep 2026 · fim-2026-09-21

Lead Signal

Belgium's December 2025 FATF Mutual Evaluation Report places the jurisdiction under enhanced follow-up: the country is rated compliant or largely compliant on 33 of 40 Recommendations, but effectiveness is assessed as largely Moderate across 11 Immediate Outcomes. The evaluation identifies a specific deficiency in virtual-asset supervision, noting the absence of a clearly designated VASP supervisor at the time of assessment, and sets a three-year roadmap centred on virtual-asset supervision and administrative-sanction deterrence. This is a technically-aligned-but-weakly-effective profile: Belgium's statute book largely matches the FATF standard, yet the follow-up mechanism signals that supervisory practice, sanctioning rigor, and outcome delivery have not kept pace with the legal architecture, particularly around newer typology vectors such as crypto-asset activity.

Other Developments

A twin-peaks supervisory model for crypto has moved from design to enforcement. The Belgian Law of 11 December 2025, in force from 3 January 2026, implements MiCA and allocates crypto-asset service provider authorisation and supervision between the FSMA (conduct) and the National Bank of Belgium (prudential, for entities already prudentially supervised). This structural allocation directly addresses the FATF's virtual-asset-supervisor gap identified in the same cycle's mutual evaluation, giving Belgium a designated authority split where previously the FATF had found none clearly designated. The transitional CASP regime for pre-existing providers expired 1 July 2026, and the FSMA has already produced concrete enforcement output from that expiry, publicly naming six unauthorised crypto-asset service providers active in the Belgian market. The naming action is the first tangible evidence that the new supervisory perimeter has teeth beyond its statutory design.

A reported shift toward more frequent public naming of AML-breaching institutions. The National Bank of Belgium is reported, in trade press only, to be planning more frequent public naming of institutions found in breach of AML rules, with the reporting explicitly linking this planned shift to FATF criticism and targeting mid-2026 implementation. No primary NBB circular confirming implementation has been located this cycle, so this remains a policy signal rather than a confirmed operational change. If implemented, it would represent a compliance-technology and active-defence response calibrated directly to the FATF's effectiveness critique, using public disclosure as a deterrence and active-defence mechanism rather than relying solely on private supervisory correspondence.

Standing beneficial-ownership position unchanged. Belgium's UBO Register continues to operate under existing 4AMLD/5AMLD-derived obligations, with no material reform or access-policy change located this cycle. This stability sits against the broader EU architecture described below.

Cross-Monitor Connections

The crypto-supervision developments here connect directly to WPM's W1a licensing and market-access tracking, where the same FSMA/NBB supervisory split and the same six-provider naming action are being tracked from a market-structure lens rather than a financial-crime lens. The FATF's virtual-asset-supervisor deficiency finding is the analytical bridge between the two views: what FIM reads as a compliance-architecture gap being closed, WPM reads as a market-access and authorisation-perimeter event. Belgium's enhanced-follow-up status and its three-year roadmap on sanctions deterrence also merit a forward watch for any WDM-relevant institutional-capacity findings, though none are evidenced this cycle.

Outlook

The roadmap attached to Belgium's enhanced follow-up status is the frame for the next several cycles: virtual-asset supervision effectiveness and administrative-sanction deterrence are the two areas FATF has flagged, and the CASP enforcement action and the NBB's reported naming-policy shift both sit squarely within that frame. Whether the NBB's reported policy shift materialises into a confirmed circular, and whether FSMA's enforcement tempo against unauthorised CASPs continues or was a one-off post-transition clearing action, are the two concrete signals to watch. Scenario framing here is illustrative only, not a prediction.

14 Sep 2026 · fim-2026-09-02

Lead Signal

Belgium has closed a structural enabler gap in crypto-asset AML/CFT supervision. The Act of 11 December 2025, in force from 3 January 2026, designates the Financial Services and Markets Authority (FSMA) and the National Bank of Belgium (NBB) as competent authorities for crypto-asset service providers and issuers under the EU Markets in Crypto-Assets Regulation, with the NBB serving as prudential authority for asset-referenced and e-money token issuers and for certain crypto-asset service providers, and monitoring AML/CFT compliance directly for the crypto-asset service providers under its supervision. This replaces the narrower, AML-driven 2022 Royal Decree registration regime that previously governed virtual-asset service providers in Belgium, a shift that is architectural rather than incidental: it moves Belgium's digital-asset sector from a registration-only AML perimeter to a full prudential-and-conduct supervisory framework spanning issuance, custody, and trading activity.

Other Developments

AML/CTF regime tracking without Belgium-specific divergence. Belgium continues to track the European Union's staggered AML Package timetable, with the Anti-Money Laundering Authority operational since mid-2025, the sixth Anti-Money Laundering Directive's beneficial-ownership register provisions due for transposition by 10 July 2026, and the AML Regulation reaching full applicability on 10 July 2027. No Belgium-specific divergence from this bloc-wide schedule surfaced this cycle beyond the sector-adjacent MiCA competence allocation described above. A lower-confidence, single-source report suggests Belgian regulators may be preparing to publicly identify banks with serious, repeated AML compliance breaches, linked to harmonised sanctions and disclosure provisions under the sixth directive and to the Authority's 2025 launch; this signal could not be corroborated against a National Bank of Belgium or FSMA primary publication this cycle and is treated as possible rather than assessed pending further sourcing.

Cross-Monitor Connections

The MiCA competence allocation is directly relevant to the crypto monitor's licensing and token-classification tracking for Belgium, since the same Act of 11 December 2025 that closes the AML enabler gap also establishes the FSMA as the crypto-asset service provider authorisation authority. The reported name-and-shame enforcement signal, if corroborated, would also carry relevance for the advennt monitor's payments-and-money-flow tracking to the extent that named institutions intersect with gambling-sector payment processing, though no such intersection is established this cycle.

Outlook

The most consequential near-term milestone is the 10 July 2026 deadline for member states, including Belgium, to transpose the sixth directive's beneficial-ownership register interconnection and tiered-access provisions; general industry practice has not yet adapted beneficial-ownership register access workflows to this standard. The reported bank name-and-shame escalation remains the key item to watch for corroboration, since a confirmed primary-source announcement would meaningfully raise the assessed confidence and materiality of that signal, whereas continued silence from the National Bank of Belgium or FSMA would leave it capped at a possible-tier finding.

Domain intelligence (D1–D8)

D1 Sanctions

no_changewatchstanding position

Sanctions Architecture and Evasion

The most significant sanctions-architecture development in this cycle is structural rather than punitive: the final phase of the coordinated G7 and EU ban on Russian-origin rough and polished diamonds took effect 1 January 2026, and a Due Diligence Statement on Diamond Origin is now required on polished-diamond customs declarations. Because Antwerp handles close to the entirety of European Union rough-diamond imports, Belgium sits at the practical enforcement point for this measure, holding a systemic role in the diamond leg of the wider sanctions architecture aimed at Russian war-financing revenue. This finding carries high confidence, resting on a Tier 1 Belgian foreign-ministry source, and it should be read architecturally: the compliance burden it creates falls on customs declarants and the trading infrastructure itself, not merely on identifiable bad actors, which is precisely the point of a chokepoint-based sanctions design.

Running alongside the diamond measure, and independently sourced, two further sanctions actions this cycle extend the pattern of unilateral United States pressure operating in parallel with the G7/EU-coordinated diamond measure. On 16 January 2026, OFAC designated twenty-one individuals and entities plus one vessel connected to Houthi oil-smuggling and financing activity. A second tranche on 23 January 2026 targeted eight entities and nine vessels forming part of Iran's shadow fleet. Both actions are corroborated by Tier 3 reporting, though the primary OFAC.gov documentation specific to these actions was not directly captured this cycle, and confidence is accordingly held at Assessed rather than High. Read together with the diamond measure, these actions demonstrate that sanctions-evasion architecture this cycle spans both a coordinated multilateral instrument and continued unilateral US designation activity, with no material divergence identified this cycle between the US, EU, and UK sanctions postures on these specific measures.

Two enabler-jurisdiction signals bear on how sanctions-evasion architecture is likely to manifest downstream, reported here as context rather than as sanctions actions in themselves. Cambodia's central bank governor issued an explicit warning of renewed FATF grey-list re-listing risk, given concrete weight by the arrest of Chen Zhi of the Prince Group and the forced liquidation of Prince Bank; this is corroborated across two independent Tier 3 outlets, though no Tier 1 FATF confirmation of actual re-listing exists yet, and confidence is held at Assessed. Separately, Laos' Golden Triangle Special Economic Zone persists as a structurally tolerated money-laundering and cyber-scam hub, with a twenty percent Lao state ownership stake and limited effective state control; the 2018 OFAC designation against the zone is stale relative to the current risk picture, and no fresh 2026 US Treasury action against the zone itself was identified this cycle.

The architectural through-line across this cycle's sanctions findings is that the most consequential development is a structural tightening of a legitimate trade chokepoint — the Antwerp diamond trade — rather than an enforcement event against a named evader. Enforcement-versus-enablement analysis should treat Belgium's posture this cycle as tightening and structural, in contrast to Laos, which remains on the enablement side of the ledger, and Cambodia, which is now more clearly enforcement-oriented than in prior cycles.

Outlook

The near-term marker to watch is whether Cambodia's FATF re-listing risk becomes a formal grey-list action, which would materially affect correspondent-banking risk pricing for Cambodian counterparties. On the diamond measure, the practical compliance question is how consistently the Due Diligence Statement on Diamond Origin is enforced at the Antwerp declaration point. The Houthi and Iran shadow-fleet designations should be expected to continue in an incremental, rolling-designation pattern; the analytically significant question is whether EU or UK sanctions authorities move to align designations, which no evidence this cycle indicates.

Judgment: No Belgium-specific or Yemen/Houthi sanctions material located this cycle; a coverage gap, not a confirmed no-change finding. Uncertain

D2 Beneficial Ownership

no_changeno_changestanding position

Beneficial Ownership and Corporate Transparency

The EU AML Package's durable architecture rests on three distinct instruments: the directly applicable AML Regulation (AMLR, Regulation (EU) 2024/1624); the sixth Anti-Money Laundering Directive (6AMLD), transposed individually by each Member State; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and progressively shifts the supervisory perimeter from purely national authorities toward a hybrid EU-level regime, including planned direct supervision of a first cohort of high-risk cross-border obliged entities. This structural fact is the durable backdrop against which this cycle's beneficial-ownership signal should be read; it is standing context rather than a single-cycle development.

Against that backdrop, this cycle's concrete signal is thin and carries low confidence. Beneficial-ownership-register provisions under 6AMLD (Articles 11 through 13 and 15) and related AMLA technical standards fall due 10 July 2026, but a third of Member States are assessed to have already missed the preceding 10 July 2025 register-access transposition deadline. All corroborating sources for this finding are Tier 4 vendor and compliance-blog commentary; no Tier 1 confirmation from the European Commission or AMLA itself was retrieved this cycle, and confidence is held accordingly low.

For Belgium specifically, the UBO register continues to operate on a case-by-case basis, releasing beneficial-ownership information by email to requesters who demonstrate legitimate interest, a posture that sits ahead of, rather than in response to, the BORIS interconnection requirements the EU-wide architecture is building toward. This is itself a low-confidence Tier 4-sourced finding, and Belgium's specific 6AMLD transposition status was not independently established this cycle.

Outlook

The 10 July 2026 register-layer deadline is the immediate marker to watch, but the more consequential question is whether the implementation gap already visible at the 2025 register-access deadline recurs at the 2026 milestone across the same cohort of Member States. Confirmation from a Tier 1 Commission or AMLA source of both the deadline's substantive content and Belgium's specific compliance posture would materially upgrade confidence in this domain for the next cycle.

Judgment: UBO register continues under existing framework; BORIS 2028 horizon items flagged but not this-cycle movement. Uncertain

D3 Enabler Jurisdictions

no_changeno_change

Judgment: No enabler-jurisdiction material for Belgium located this cycle. Uncertain

D4 Conflict Finance

no_changeno_changestanding position

Conflict Finance and Extractive-Industry Integrity

This cycle's conflict-finance signal is a single, high-confidence structural finding rather than a broad typology sweep: the final phase of the coordinated G7 and EU ban on Russian-origin rough and polished diamonds took effect 1 January 2026, with a Due Diligence Statement on Diamond Origin now required on polished-diamond customs declarations. Because Antwerp handles close to the entirety of European Union rough-diamond imports, this measure directly implicates Belgium's extractive-trade sector as the practical chokepoint through which Russian diamond-export revenue — a documented war-financing stream for the conflict in Ukraine — must now pass a heightened due-diligence bar. The finding rests on a Tier 1 Belgian foreign-ministry source and is held at high confidence.

No further conflict-finance or extractive-industry-integrity evidence specific to Belgium beyond this diamond-sector sanctions finding was located this cycle; this is an acknowledged gap rather than an assessment that no further exposure exists. The extractive-industry-integrity reading of the diamond measure is that it functions as revenue-denial architecture at the trade-infrastructure level rather than as a prosecution or asset-freeze action against a named conflict-finance actor.

Outlook

The question for the next cycle is whether enforcement data becomes available showing how the Due Diligence Statement on Diamond Origin requirement is applied in practice at the point of customs declaration, and whether that data indicates material disruption to previously undetected Russian-origin diamond flows through Antwerp. Absent new evidence, this domain should be treated as stable-and-structural rather than escalating.

Judgment: No conflict-finance material for Belgium located this cycle. Uncertain

D5 Crypto / Digital Assets / Financial Innovation

material_changematerial_change

Crypto / Digital Assets / Financial Innovation

Belgium's digital-asset supervisory picture reached a structural inflection point with the close of the MiCA transitional authorisation window on 1 July 2026. Under that regime, a crypto-asset service provider lawfully operating under Belgian national law before 30 December 2024 could continue trading pending authorisation or refusal, or until the backstop date, whichever came first. The backstop has now passed, and the Financial Services and Markets Authority's own account is unambiguous on the resulting population: to date, no crypto-asset service provider holds an authorisation granted by the FSMA in Belgium. Six firms that had been operating during the transitional window have since been added to the regulator's public list of unauthorised, potentially fraudulent providers, a mechanism distinct from licence revocation or prosecution but one that carries real market consequences by publicly marking those firms as outside the regulated perimeter.

This finding sits in tension with a separate data point drawn from a commercial register tracking CASP authorisation status across EU member states, under the European Securities and Markets Authority's Article 110 non-compliant-provider file. That file held 173 total entries at its 30 September 2026 update, with Italy's Consob contributing the largest single share at 164 and Belgium's FSMA contributing six. The six-entry Belgian figure is consistent with the FSMA's own fraudulent-list growth, which lends some corroboration to the zero-authorisation account, but the underlying record notes that a separate vendor snapshot elsewhere describes two home-authorised Belgian CASPs for the same period. That discrepancy has not been reconciled against ESMA's own register this period, and it should be read as an open question rather than resolved in either direction: either the FSMA's public communications have not yet caught up with a quiet domestic authorisation, or the vendor tracker is describing a different population (for example, foreign-authorised firms passporting into Belgium rather than domestically-authorised ones).

The structural significance of a jurisdiction with zero confirmed domestic crypto-asset authorisations, roughly a year into MiCA's substantive operation, extends beyond Belgium's own market. MiCA's passporting architecture means that firms authorised anywhere in the European Economic Area can serve Belgian clients without a separate Belgian authorisation, so the absence of a domestic CASP population does not mean an absence of crypto-asset activity reaching Belgian consumers; it means that supervisory responsibility for firms serving the Belgian market is concentrated almost entirely outside Belgium's own regulator. That is precisely the kind of enablement-by-passporting pattern that deserves scrutiny independent of any enforcement action, because no enforcement action is likely to be visible in a structure where the relevant supervisory relationship is held by another member state's authority. Whether this reflects deliberate reliance on the single-market passporting mechanism, a genuinely thin pipeline of domestic applicants, or slow authorisation processing at the FSMA cannot be determined from what has been gathered this period.

Outlook

The most immediate open question is reconciliation: whether the FSMA's zero-authorisation statement and the vendor tracker's two-CASP count for Belgium describe the same underlying population at different points in time, or genuinely different populations. A direct comparison against ESMA's own Article 110 register, rather than secondary trackers on either side, would resolve this. Separately, the growth of the FSMA's fraudulent-CASP list to six entries in the weeks following the transitional window's close suggests that enforcement-adjacent activity (public listing rather than prosecution) may continue as firms that operated during the transitional period either exit the Belgian market, secure authorisation, or are added to the warning list. Given the passporting dynamic described above, any assessment of Belgium's digital-asset risk exposure that looks only at domestically-authorised firms will understate the scale of EU-passported activity actually reaching Belgian consumers.

Judgment: Belgium's MiCA CASP transitional regime closed 1 July 2026 with zero FSMA-authorised domestic CASPs on FSMA's own account; FSMA's fraudulent-CASP list grew to six entries. A separate vendor register snapshot describes two home-authorised CASPs for the same period, unreconciled this cycle. Uncertain

D6 Compliance Technology & Active Defence

no_changeno_changestanding position

Compliance Technology and Active Defence

A reported policy shift at the National Bank of Belgium toward more frequent public naming of AML-breaching institutions is this cycle's D6-relevant signal, though it remains unconfirmed at the primary-source level. Trade press reporting describes the NBB as planning to increase the frequency with which it publicly names institutions found in breach of AML rules, with the reporting explicitly tying the planned shift to criticism the jurisdiction received from the FATF, and targeting implementation around mid-2026. No primary NBB circular or supervisory statement confirming that this policy has actually been adopted has been located this cycle; the finding rests on a single trade-press source and is accordingly held at Uncertain confidence rather than Confirmed.

If implemented as reported, a more frequent public-naming policy would function as a compliance-technology and active-defence mechanism in the architecture-over-incident sense: it uses reputational disclosure as a supervisory lever, applied systematically rather than reactively, and it would represent Belgium's regulator adapting its own enforcement toolkit in direct response to an external effectiveness critique rather than waiting for the next mutual-evaluation cycle to prompt reform. The absence of enforcement action to date under this specific policy is itself worth noting as a signal: a planned but not-yet-implemented transparency policy is analytically distinct from either a confirmed rule change or a demonstrated absence of regulatory appetite, and the honest position this cycle is that Belgium sits in the former category.

This finding should be read alongside the FSMA's own public-naming action against six unauthorised CASPs (see the D5 sub-brief) as evidence of a broader, if unevenly confirmed, directional trend toward public disclosure as a compliance tool across Belgian financial regulators.

Outlook

The key test for the next cycle is whether a primary NBB circular or public statement emerges confirming implementation of the reported naming policy. Absent that confirmation, this remains a watch item rather than a material development. Illustrative orientation only; not a prediction of NBB policy outcomes.

Judgment: No RegTech/AI-compliance development specific to Belgium located this cycle. Uncertain

D7 AML/CTF Regime

stableactive

AML/CTF Regime

Belgium's core AML/CFT architecture shows no structural change this period: the Act of 18 September 2017 remains the governing statute, the financial intelligence unit known as CTIF in French and CFI in Dutch remains the designated reporting authority, and since 30 September 2024 that unit has received suspicious-transaction declarations exclusively through the goAML electronic platform, with no residual paper or email filing route. This baseline rests on convergent secondary commentary rather than a directly-retrieved primary text this period, which is worth noting as a sourcing characteristic rather than a substantive gap: multiple independent descriptions agree on the same statutory and institutional facts, which supports treating the baseline as probable even without an elevation to confirmed status.

The one genuinely new development inside the AML/CFT regime this period is administrative rather than statutory. A National Bank of Belgium circular dated 16 February 2026, identified in the underlying record as Circular NBB_2026_02, is reported to have added a seventh annex to the Bank's existing periodic questionnaire on the prevention of money laundering and terrorist financing. That new annex is described as an eligibility form tied to Article 12 of the regulation establishing the EU's Anti-Money Laundering Authority, the body being built to take over direct supervision of a subset of cross-border obliged entities across the Union. The practical effect, as reported, is that Belgian banks, payment institutions, investment firms and other obliged cross-sector entities completing their routine periodic AML questionnaire will now also be asked to supply information bearing on whether they fall within the population AMLA may select for direct supervision in its anticipated 2027 selection round.

This is a small but structurally legible move. AMLA's mandate build-out has itself been progressing at the EU level: the European Banking Authority formally completed the transfer of all of its AML/CFT-related mandates to AMLA on 1 January 2026, even though AMLA's own full operational capacity is not expected before 2028. Reading the NBB's February 2026 questionnaire addition against that backdrop, it looks like an early piece of the plumbing a national supervisor needs in place well before AMLA is itself fully staffed and operating: the eligibility data has to be collected from obliged entities before AMLA can use it to decide who it will supervise directly. Nothing about this addition changes Belgium's existing reporting thresholds, CDD/EDD tiers, or the goAML-only filing channel; it adds one more data-collection exercise layered onto an already-functioning periodic questionnaire.

The underlying primary circular text was not independently retrieved this period, so its existence and precise content rest on a single secondary description. That is a sourcing limitation worth flagging rather than a reason to discount the finding, given that it is consistent with, and plausibly anticipates, the EU-level AMLA transition that is independently and separately documented.

Outlook

The clearest forward marker is the 2027 AMLA direct-supervision selection round, for which the February 2026 NBB questionnaire annex appears to be preparatory groundwork. Whether Belgium's banks, payment institutions and investment firms see any further administrative changes ahead of that round, and whether any Belgian-domiciled entity is ultimately selected for direct EU-level supervision rather than continued purely national oversight by the NBB, are the two questions this baseline-stable but quietly-shifting regime will answer over the next one to two years. Belgium's core statutory and institutional AML/CFT architecture is not expected to change independently of that EU-level process.

Judgment: Belgium's AML/CFT baseline (Act of 18 September 2017, CTIF-CFI, goAML-only reporting since 30 September 2024) is unchanged; NBB added a new AMLA Article 12 eligibility annex to its periodic questionnaire via Circular NBB_2026_02 ahead of the 2027 AMLA selection round. Probable

D8 Commercial Activity

no_changeno_changestanding position

Commercial Activity

Brussels-based fintech Chift, which provides a financial-data-connectivity API layer for European software, closed a EUR 10.5 million Series A funding round in September 2026, led by BlackFin Capital Partners. This is a commercial capital-flow event rather than a regulatory development, but it is read here through the financial-integrity lens because Chift's connectivity-layer business model sits adjacent to the AML/CFT compliance perimeter: firms providing financial-data-connectivity infrastructure to regulated institutions are themselves a category institutions should consider when assessing their third-party and vendor risk exposure, even where the vendor itself is not a regulated AML-obliged entity.

This funding round should be read alongside the continued tracking of Belgian crypto market-maker Keyrock at a Series C-plus valuation profile exceeding $1 billion, illustrating that private capital continues to flow into Belgian financial-infrastructure firms broadly, spanning both regtech/connectivity vendors like Chift and crypto-native infrastructure firms like Keyrock. Neither transaction is itself a regulatory or enforcement event, and neither alters the AML/CFT obligations applicable to Belgian-regulated institutions, but both illustrate the commercial environment in which Belgium's financial-integrity regulatory developments this cycle — the NBB's Wise naming and the FSMA's post-MiCA enforcement — are occurring.

Outlook

The item to watch from a commercial-activity perspective is whether continued capital inflow into Belgian fintech and crypto-infrastructure firms generates additional third-party vendor-risk considerations for the regulated institutions that integrate with them, particularly as connectivity-layer providers like Chift expand their footprint across European financial institutions' technology stacks.

Judgment: No financial-integrity-market commercial activity specific to Belgium located this cycle. Uncertain

Regulatory horizon

In Force2026-Q4 · ±quarter

CRD6 transposition law of 22 July 2026

NBB supervisory powers, sanctions regime and third-country branch rules updated per CRD6 transposition; ESG risk provisions also included.

National Bank of Belgium / Belgian Parliament Source

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

Role action cards

MLRO

Belgium's NBB periodic AML questionnaire gained a new AMLA Article 12 eligibility annex via a February 2026 circular.

Reporting obligations under the existing periodic questionnaire framework have not changed in substance, but institutions should expect to supply additional eligibility data relevant to the EU's 2027 direct-supervision selection process when next completing the periodic filing.

2 evidence refs

Compliance

Belgium's domestic crypto-asset authorisation population stands at zero per FSMA's own account, with an unreconciled vendor count of two.

Any Belgian counterparty-screening or product-risk assessment that assumes a populated domestic CASP authorisation list should be checked against the FSMA's own public statement rather than a secondary vendor register, given the unresolved discrepancy.

2 evidence refs

Board

Belgium's AML/CFT institutional baseline is stable while EU-level AMLA transition preparations begin to surface in national supervisory practice.

The governance significance is structural rather than immediate: Belgium's existing statute and FIU are unchanged, but the appearance of AMLA-eligibility data collection in a national instrument signals the early stages of a supervisory architecture shift that may eventually bring select cross-border entities under direct EU oversight.

2 evidence refs

CTO

Belgium shows zero FSMA-authorised domestic crypto-asset service providers as of the 1 July 2026 MiCA transitional-window close.

Technical and platform risk assessments for crypto-asset infrastructure touching the Belgian market should account for the fact that EU passporting, not domestic authorisation, is the operative supervisory mechanism for most crypto-asset activity reaching Belgian users.

2 evidence refs

Risk

A structural gap between domestic crypto-asset supervisory authorisation and actual market exposure is emerging in Belgium.

Zero domestically-authorised CASPs alongside continued EU-passported market access represents a concentration of supervisory responsibility outside Belgium's own regulator, a pattern worth tracking as an emerging-exposure signal rather than a resolved risk.

2 evidence refs

Audit

A new AMLA Article 12 eligibility annex within Belgium's periodic NBB AML questionnaire was reported via a February 2026 circular not independently retrieved this period.

Audit trail documentation for Belgian periodic AML questionnaire responses should be checked for the presence of the new annex once the underlying circular is independently confirmed, since the finding currently rests on a single secondary source.

1 evidence refs

Scenario sketches

AMLA direct-supervision transition reshaping national AML questionnaires

Illustrative orientation only: as the EU's Anti-Money Laundering Authority moves from mandate-receipt toward full operational capacity by 2028, national supervisors across the bloc may increasingly layer AMLA-eligibility data collection onto their existing periodic AML instruments, as Belgium's National Bank appears to have done via its February 2026 circular annex. If this pattern generalises, cross-border obliged entities in multiple member states could face a wave of similar administrative additions ahead of AMLA's 2027 selection round, well before the Authority itself is fully staffed. This is an illustrative structural possibility, not an observed multi-jurisdiction trend and not a prediction of AMLA's eventual supervisory scope.

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	no_change	No Belgium-specific material located; a coverage gap, not a confirmed no-change finding.
T2 · EU AML Package / AMLA	watch	NBB added an AMLA Art. 12 eligibility annex to its 2026 periodic AML questionnaire (Circular NBB_2026_02), operationalising AMLA/AMLR transition ahead of 2027 selection.
T3 · FATF Grey List	no_change	Belgium is not on the FATF grey list; no new plenary outcome located this cycle.
T4 · Beneficial-Ownership Register Status	no_change	UBO register continues under existing framework; BORIS/2028 items are horizon, not this-cycle movement.
T5 · Crypto & Digital-Asset Integrity	watch	MiCA transitional regime closed 1 July 2026 with zero FSMA-authorised CASPs on FSMA's own account and six fraudulent-list entries; unreconciled against a vendor count of two.
T6 · Sanctions Regime Divergence	no_change	No Belgium-specific sanctions-divergence development located this cycle.

Registers

Enforcement actions

16 Dec 2025
9 Jun 2026
19 Feb 2025
26 Mar 2026
FATF adopted Belgium's mutual evaluation report, the first assessment completed under the new time-bound, risk-based 5th round methodology (alongside Malaysia), assessing technical compliance and effectiveness across all 11 immediate outcomes. 16 Dec 2025
A Belgian court convicted seven individuals of an international ISIS support network that used cryptocurrency-based laundering to fund weapons and CBRN-E precursor procurement and support detained fighters in Syria and Central Asia, supported by Europol's ECTC. 9 Jun 2026
Belgian courts dismissed JPMorgan's attempt to secure release of approximately $2.4 billion blocked under EU sanctions because the underlying transactions involved Russia's sanctioned central bank; the Belgian Treasury maintained the freeze despite the funds not belonging directly to a sanctioned entity. 19 Feb 2025
Euroclear eased its internal rules governing payments linked to frozen Russian securities, allowing certain transactions benefiting non-US investors to proceed without requiring separate US Treasury OFAC authorisation, following consultation with authorities. 26 Mar 2026

Sanctions changes

23 Oct 2025
24 May 2026
1 Dec 2025
1 Jan 2026
16 Jan 2026
23 Jan 2026
30 Jun 2026
EU 19th sanctions package (23 Oct 2025) targeted Russian energy, third-country banks and crypto providers, including designation of the Grinex exchange, which is central to Belgian-relevant Euroclear/EU financial-infrastructure sanctions exposure. 23 Oct 2025
EU 20th sanctions package (adopted 23 April 2026, crypto measures effective 24 May 2026) banned an entire category of Russian-established crypto-asset service providers and prohibited support for the RUBx ruble-backed stablecoin and Russia's digital ruble CBDC. 23 Apr 2026
The EU Council decided in December 2025 to prohibit, on a temporary basis, any transfer of immobilised Central Bank of Russia assets held in the EU (predominantly at Belgium-based Euroclear) back to Russia, directly implicating Belgian custodial infrastructure. 1 Dec 2025
Euroclear (Belgium-based) eased payment rules for holders of frozen Russian foreign-currency bonds, permitting certain non-US-investor transactions to proceed without separate OFAC authorisation, following consultation with Belgian/EU authorities. 26 Mar 2026

Regulatory horizon (register)

AMLD6 beneficial-ownership register transposition deadline
AMLD6 beneficial-ownership register transposition deadline
CRD6 transposition law of 22 July 2026
AMLR (Reg 2024/1624) direct application in Belgium
AMLA direct supervision of high-risk cross-border entities begins
MiCA transitional CASP authorisation window closes
Belgium's FATF enhanced follow-up progress report
6AMLD national transposition alignment with AMLR

Active schemes

[CRITICAL] Euroclear as epicentre of frozen Russian sovereign assets
[HIGH] Antwerp diamond trade as Russian-diamond evasion and traceability node
[HIGH] ISIS crypto-financing network for weapons and CBRN procurement
Beneficial-ownership register access restriction
[HIGH] Unsupervised VASP sector as laundering conduit

Sources

Coverage gaps

fim-int-2026-07-07-G001: No primary-source confirmation exis…

fim-int-2026-07-07-G001: No primary-source confirmation exists of the operational status and scope of FSMA and National Bank of Belgium crypto-asset service provider authorisation activity beyond a single T1 website reference. [resolved]

fim-int-2026-07-07-G002: No reconciled primary Euroclear fin…

fim-int-2026-07-07-G002: No reconciled primary Euroclear financial disclosure exists to settle the discrepancy between the 258 billion euro, 200 billion euro, and 194 billion euro frozen-asset figures reported across sources. [resolved]

fim-int-2026-07-07-G003: The outcome of Euroclear Brussels c…

fim-int-2026-07-07-G003: The outcome of Euroclear Brussels commercial-court countersuit against the Bank of Russia, filed June 2026, is not yet established and would materially affect the sanctions-architecture risk trajectory. [resolved]

fim-int-2026-07-07-G004: No Belgian Official Gazette or prim…

fim-int-2026-07-07-G004: No Belgian Official Gazette or primary legislative text for the Law of 11 December 2025 implementing MiCA has been collected to confirm the exact CASP authorisation timeline. [resolved]

fim-int-2026-07-07-G005: No IMF Financial Sector Assessment …

fim-int-2026-07-07-G005: No IMF Financial Sector Assessment Program document or sector-specific risk assessment for Belgium private banking, TCSP, or fund management sectors has been identified. [resolved]

fim-int-2026-07-07-G006: No T1 evidence of state-level compl…

fim-int-2026-07-07-G006: No T1 evidence of state-level complicity exists to support or refute the original CRITICAL severity_preliminary assigned to the ISIS crypto-financing network conviction. [resolved]

fim-int-2026-08-05-G001: No BE-specific National Risk Assess…

fim-int-2026-08-05-G001: No BE-specific National Risk Assessment reference was located this cycle for jurisdiction_baselines[BE].nra_reference. [resolved]

fim-int-2026-08-05-G002: No further D4 conflict-finance doma…

fim-int-2026-08-05-G002: No further D4 conflict-finance domain evidence for Belgium beyond the diamond-sector sanctions finding was located this cycle. [resolved]

fim-int-2026-08-05-G003: No direct T1 FSMA primary bulletin …

fim-int-2026-08-05-G003: No direct T1 FSMA primary bulletin URL was retrieved confirming the six-CASP warning-list action; corroboration rests on Tier 3/4 press only. [resolved]

fim-int-2026-08-05-G004: No direct T1 AMLA/European Commissi…

fim-int-2026-08-05-G004: No direct T1 AMLA/European Commission primary-source URL was retrieved for the 10 July 2026 register-layer deadline; corroboration rests on Tier 4 vendor/compliance sources only. [resolved]

fim-int-2026-08-05-G005: D6 (Compliance Technology and Activ…

fim-int-2026-08-05-G005: D6 (Compliance Technology and Active Defence) coverage remains thin for this cycle; no BE-specific RegTech/AI-compliance development was identified. [resolved]

fim-int-2026-09-02-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-02-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): Tier D jurisdiction watch (KH, LA, MX, CO) and the Houthi/Yemen sanctions channel were not actively searched this cycle given the pooled union search budget concentrated on Belgium. [resolved]

fim-int-2026-09-02-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-02-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): The reported Belgian 'name and shame' AML enforcement escalation could not be corroborated against an NBB or FSMA primary publication this cycle and remains capped at Possible confidence. [resolved]

fim-int-2026-09-21-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-21-G001 ({'scheme': 'financial_integrity', 'value': 'D6'}): No primary NBB circular located confirming implementation of the reported 'name and shame' policy shift; currently sourced only from trade press. [resolved]

fim-int-2026-09-21-G002: Tier D watch jurisdictions (KH, LA,…

fim-int-2026-09-21-G002: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively researched this cycle given the BE-bound dispatch scope; status remains awaiting_primary_source rather than no_source. [resolved]

fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Belgium-specific national transposition instrument for the 6AMLD beneficial-ownership register development deadline (10 July 2026) was located this cycle. [resolved]

fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No primary regulator or enforcement instrument corroborates the diamond-sector structural AML exposure claim beyond a single T4 industry-training source. [resolved]

fim-int-2026-09-28-G003: No Belgium-specific sanctions-evasi…

fim-int-2026-09-28-G003: No Belgium-specific sanctions-evasion (D1) or compliance-technology (D6) material was located this cycle. [resolved]

fim-int-2026-10-11-G001: No primary FATF/APG/GAFILAT plenary…

fim-int-2026-10-11-G001: No primary FATF/APG/GAFILAT plenary material located linking Cambodia, Laos, Mexico or Colombia status to Belgium specifically within this window. [resolved]

fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No BGC-equivalent BE National Bank Sanctions Committee decision page was retrieved this cycle confirming the Wise Europe SA naming at primary source. [open]

fim-int-2026-10-18-G002: Tier D jurisdictions (KH, LA, MX, C…

fim-int-2026-10-18-G002: Tier D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle due to pooled-budget prioritisation of BE; recorded as awaiting_primary_source, not no_source. [open]

fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): No D3 (enabler jurisdictions) or D4 (conflict finance) substantive finding for Belgium was located this cycle. [open]

fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): Tier-D watch jurisdictions (KH/LA/MX/CO) and the standing Yemen/Houthi UN Panel/OFAC/OFSI check were not actively searched this cycle given the union's single-jurisdiction binding. [open]

fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): FSMA's T1 statement of zero authorised CASPs and a T3 vendor tracker's count of two home-authorised CASPs for Belgium describe overlapping periods but were not reconciled against ESMA's own register this cycle. [open]

fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Circular NBB_2026_02 itself was not directly retrieved this cycle; its existence and content rests on a single T3 secondary source. [open]

FIM-GAP-001 (D5): No Belgian authority is currently designat…

FIM-GAP-001 (D5): No Belgian authority is currently designated to licence and supervise virtual asset service providers, leaving exchange, custody and transfer activity in a very high-risk sector without dedicated AML/CFT oversight.

FIM-GAP-002 (D6): Belgian financial supervisors make very li…

FIM-GAP-002 (D6): Belgian financial supervisors make very limited use of administrative sanctions and publish decisions in near-anonymous form, undermining the deterrent and educational value of the enforcement regime.

FIM-GAP-003 (D3): Resource constraints have led Belgium to p…

FIM-GAP-003 (D3): Resource constraints have led Belgium to prioritise money-laundering investigations based on the profitability/ease of asset recovery rather than case complexity, systematically deprioritising sophisticated transnational organised-crime laundering networks.

FIM-GAP-004 (D2): Belgium's UBO register restricts public ac…

FIM-GAP-004 (D2): Belgium's UBO register restricts public access to holders of Belgian citizenship, residency-linked eID or a Belgian tax number, and imposes access fees — a design that historically fell short of the '5AMLD-era open-access model'; no evidence of reform was identified within the 18-month baseline window.

FIM-GAP-005 (D3): Detection of illicit activity via hawala a…

FIM-GAP-005 (D3): Detection of illicit activity via hawala and informal value-transfer channels remains limited despite Belgium's satisfactory general risk understanding, per the FATF's December 2025 mutual evaluation.

FIM-GAP-006 (D6): No IMF Financial Sector Assessment Program…

FIM-GAP-006 (D6): No IMF Financial Sector Assessment Program (FSAP) document or sector-specific risk-assessment publications (private banking, TCSP, fund management) specific to Belgium were identified within available sources for this baseline; the FSAP and sector-RNA fields in nra_reference were left empty pending future access to such documents.

Evidence

Confidence-tiered claims

contradictorily recorded as both fully communicated and subject to an open EU infringement procedure as of 2026-08-07 [Source 1]

Probable · 1 source

Named publicly by NBB for missed 31 March 2026 AML remediation deadline; new deadline 31 January 2027 [Source 1]

Probable · 1 source

No crypto-asset service provider holds an FSMA-granted MiCA authorisation as of FSMA's mid-2026 statements; six unauthorised firms added to fraud list 2026-07-06 [Source 1]

Probable · 1 source

Automated website-blocking system credited with preventing 80,000 potential fraud victims; 51 new fraudulent platforms added to warning list on 2026-09-24 [Source 1]

Probable · 1 source

EUR497.1 million raised across 74 disclosed rounds in H1 2026, fintech-led at EUR135.3 million [Source 1]

Probable · 1 source

Wise Europe SA publicly named under NBB's 2026 name-and-shame AML publication policy (Art 98/1, AML Law of 18 September 2017) for CDD shortcomings and a missed 31 March 2026 remediation deadline tied to an 8 July 2025 order [Source 1]

Probable · 1 source

FATF's December 2025 mutual evaluation found Belgium's AML/CFT/CPF system technically largely aligned with the FATF Recommendations but under-resourced in effectiveness, with no authority designated to license or supervise VASPs at the time of the on-site visit [Source 1]

Probable · 1 source

No authority in Belgium is designated to license or supervise virtual asset service providers, per FATF's 2025 MER [Source 1]

Probable · 1 source

Law of 22 July 2026 transposes Directive (EU) 2024/1619 (CRD6) on NBB supervisory powers, sanctions, third-country branches and ESG risks [Source 1]

Probable · 1 source

FSMA added six unauthorised crypto-asset service providers to its fraudulent-provider warning list from 6-10 July 2026, following expiry of the MiCA transitional regime on 1 July 2026 [Source 1]

Probable · 1 source

Brussels-based fintech connectivity-layer startup Chift raised a EUR 10.5 million Series A in September 2026, led by BlackFin Capital Partners [Source 1]

Probable · 1 source

Zero FSMA-granted domestic CASP authorisations as of FSMA's post-1-July-2026 transitional-period notice; six unauthorised firms added to FSMA's public fraudulent-CASP list [Source 1]

Uncertain · 1 source

Circular NBB_2026_02 (16 February 2026) added a seventh annex, an AMLA Article 12 eligibility form, ahead of the 2027 AMLA direct-supervision selection round [Source 1]

Probable · 1 source

Act of 18 September 2017 remains governing statute; CTIF-CFI is designated FIU; goAML-only STR/SAR reporting since 30 September 2024, with no paper or email route retained [Source 1]

Probable · 1 source

AMLA completed receipt of EBA's AML/CFT mandates on 1 January 2026; full operational status expected only by 2028 [Source 1]

Uncertain · 1 source

173 total entries at the 30 September 2026 update; Belgium's FSMA reported 6 [Source 1]

Uncertain · 1 source

Belgium placed in FATF enhanced follow-up after its 2025 mutual evaluation; R.24/R.25 rated Partially Compliant on beneficial-ownership transparency of legal persons. [Source 1]

Probable · 1 source

UBO register operating since 2018 with reported ~98% registration coverage; FATF flags verification/discrepancy-notification follow-up as under-prioritised. [Source 1]

Uncertain · 1 source

EU Commission transposition monitor (as of 7 August 2026) lists Belgium both as having fully communicated AMLD6 transposition and, separately, among states facing an infringement procedure for non-communication/incompleteness. [Source 1]

Disputed · 1 source

AMLR becomes directly applicable and AMLD6 full transposition is due by 10 July 2027. [Source 1]

Probable · 1 source

Belgium's crypto-related AML perimeter now runs through the MiCA regime established by the Law of 11 December 2025, rather than a bespoke national AML gateway. [Source 1]

Uncertain · 1 source