What’s new in AML and MAR: Key financial crime and regulatory insights for November 2025

In recent months, financial institutions have needed to adapt to new regulations and developments in AML and market abuse supervision across Europe and beyond. November 2025 has brought a series of significant updates.

Below, we break down three important developments that firms should be aware of, why they matter, and what they mean for AML and MAR compliance teams going forward.

Did you miss the updates for October? You can find the article here, where we discuss AMLR, new standardised guidelines around sanctions screening, and instant payments and compliance.

1. The UK makes identity verification mandatory at Companies House

In one of the most significant changes to the UK’s corporate transparency regime in decades, Companies House has activated mandatory identity verification requirements for all new directors and persons of significant control (PSCs). 

Under the new rules, anyone forming or controlling a UK company must verify their identity. Existing directors and PSCs (an estimated seven million individuals) will be phased in over the coming year. 

The reform was introduced to address the registry's historic weaknesses, which for years allowed false information to be filed with little to no scrutiny. 

In theory, the move will reduce long-standing vulnerabilities that have been exploited for money laundering and other illicit financial activity.

For AML teams, the implications are significant. The availability of verified identity data directly from the corporate registry will provide a more reliable source when carrying out KYC processes and risk assessments. 

It will also help financial institutions connect corporate activity to real individuals rather than proxies or opaque offshore structures. 

However, to date, only a small fraction of individuals have completed verification, so there could be operational disruption as enforcement ramps up.

Verification will not eliminate all avenues for abuse, but it does make it more difficult and costly to misuse UK corporate structures. 

For institutions that rely heavily on Companies House data to support onboarding and monitoring, these reforms should be integrated into risk frameworks and screening workflows as soon as possible. 

The quality of corporate data is improving, but firms must ensure their systems and processes are prepared to leverage it effectively.

2. ESMA highlights major discrepancies in enforcement across EU markets

In its latest annual review of enforcement activity across the EU, the European Securities and Markets Authority (ESMA) has identified persistent differences in how national competent authorities (NCAs) exercise their sanctioning powers. 

Despite a shared regulatory framework under MAR and MiFID II, NCAs vary widely in terms of fine amounts and frequency, as well as types of sanctions issued.

In 2024, NCAs imposed €100 million in administrative fines, up from €71 million the previous year. 

Germany issued the single largest fine at €12.9 million for a violation of Article 17(1) of the Markets in Financial Instruments Directive (MiFID II). 

MAR enforcement was particularly prominent, with 377 separate actions across 24 member states. These cases most commonly involved market manipulation, insider trading and managers’ transactions. MiFID II enforcement was also high, with Greece, Hungary and Romania among the most active jurisdictions.

For firms operating across borders, these findings show that uneven enforcement is to be expected, as well as reinforcing that MAR risks continue to be a priority area for regulators, especially in areas such as insider trading.

Compliance teams should ensure their MAR and MiFID II frameworks are robust across all jurisdictions in which they operate. They should not rely on local enforcement leniency as an indicator of supervisory expectations. 

ESMA’s continued push for harmonisation, including through ongoing common supervisory actions, suggests that regulatory scrutiny will only increase.

3. Sweden launches a new Financial Intelligence Centre and closes 400 bank accounts

Sweden has formally launched its new Financial Intelligence Centre. The centre’s purpose is to strengthen national efforts to combat money laundering and criminal financial activity through more coordinated collaboration between authorities and the financial sector. 

Even in its early days, the Financial Intelligence Centre’s investigations have led to the closure of 400 bank accounts suspected of being linked to illicit financial activity. 

The initiative builds on earlier public-private collaboration models, particularly the SAMLIT pilot project, which improved cooperation between banks and law enforcement through structured information sharing. 

Its creation shows that Sweden, like many other European jurisdictions, is ramping up its approach to financial crime prevention, and moving from a reactive to a more data-driven approach. 

For financial institutions, the implications are twofold. First, supervisory expectations around suspicious activity reporting and data quality will rise, as authorities now have the capacity to act more swiftly on intelligence received from banks. 

Second, institutions should expect tighter scrutiny of account activity and a greater emphasis on accuracy and speed in their AML monitoring processes.

Banks operating in Sweden, in particular, should take this development as a cue to review their transaction monitoring systems and ensure their data quality supports actionable intelligence. 

The new centre’s early activity demonstrates that authorities are prepared to intervene rapidly where financial crime risks are identified.

Staying a step ahead of financial crime

Looking at the bigger picture, November’s developments show that the regulatory landscape across Europe and beyond is becoming more assertive, data-driven, and less tolerant of compliance gaps.

For AML and MAR teams, these updates are a reminder that financial crime risk is evolving quickly and that compliance frameworks must evolve with it. 

Stronger identity verification, more reliable corporate data, enhanced market abuse surveillance, and closer collaboration with authorities are becoming essential components of effective financial crime prevention.

Institutions that invest early in automated AML and MAR solutions will be best positioned to meet these rising expectations while staying ahead of regulatory change.

Book a consultation with our compliance experts today to learn how Trapets’ RegTech solutions can help you stay compliant without sacrificing efficiency.