Key points
- 01
On 1 January 2026, the FMA took over the OeNB’s responsibilities for financial sanctions supervision in the Austrian financial sector.
- 02
EBA/GL/2024/14 and EBA/GL/2024/15 have applied since 30 December 2025 – including regular testing of screening systems and their settings.
- 03
Institutions need to demonstrate why their systems and configurations are appropriate for the risks they face.
Why alert volumes do not prove screening effectiveness
When did you last test what your sanctions screening system fails to detect? Alert volumes and completed case reviews tell you how much work your system generates. They do not, by themselves, establish how reliably it identifies sanctioned persons and entities.
What changed in Austrian sanctions supervision
This distinction matters in Austria’s new supervisory setting. On 1 January 2026, the FMA took over the OeNB’s responsibilities for financial sanctions supervision in the Austrian financial sector, bringing sanctions and AML/CFT oversight together under one authority.
Which EBA guidelines apply to screening systems
The regulatory expectations are specific. EBA/GL/2024/14 addresses sanctions governance, responsibilities and internal controls. EBA/GL/2024/15 provides more detailed expectations for payment service providers and crypto-asset service providers, including regular testing of screening systems and their settings. Both have applied since 30 December 2025. Institutions need to demonstrate why their systems and configurations are appropriate for the risks they face.
How the FMA tests screening performance
To introduce a common standard in the Austrian market, the FMA has teamed up with a British AML analytics group and tested the screening systems of some Austrian financial entities. The FMA’s screening exercise puts system performance directly under scrutiny. For management and compliance officers, the practical questions are straightforward: Which test cases were missed? Why were they missed? What needs to change – and does the change actually improve detection?
What institutions should test before the supervisor asks
Institutions that have not had the “good fortune” of being selected by the regulator need not wait for their turn. The same questions are worth answering before the supervisor asks them.
How Compliance Networks supports testing and benchmarking
At Compliance Networks, we test sanctions screening and AML transaction monitoring systems using synthetic data and defined scenarios. We assess detection gaps and false positives, benchmark results across systems, configurations and test cycles, and translate the findings into concrete recommendations. Where required, we also support implementation and retesting.
“A detection gap requires an explanation; a proposed adjustment requires evidence that it works.”
Our experience in supervision and senior compliance roles informs how we interpret the results: a detection gap requires an explanation; a proposed adjustment requires evidence that it works. Reducing alert volumes is useful only if relevant risks remain reliably detected.
Contact Compliance Networks to scope a testing and benchmarking exercise for your systems – with documented findings, clear priorities and practical support for improvement.
About the authorStephan Klinger, Partner & Co-FounderFormer Head Legal Advisor of the Oesterreichische Nationalbank and head of the national competent authority for the enforcement of EU financial sanctions. Expertise in financial sanctions, EU financial regulation and governance.
