New AMLA Regulation
The EU’s New AML Framework: The AML Package and the Establishment of AMLA
In 2024, the European Union completed a far-reaching reform of its anti–money laundering and counter–terrorist financing (AML/CFT) framework—known as the AML Package. Beyond strengthening existing obligations, the reform introduces a new EU-level supervisory authority, the Anti-Money Laundering Agency (AMLA), headquartered in Frankfurt. AMLA will commence its supervisory activities on 1 January 2028, marking a new era of centralised AML/CFT supervision within the European Union.
This overview outlines the components of the AML Package, its main implications, and key steps that obliged entities should take to prepare.
1. Overview of the AML Package
The AML Package comprises four legislative instruments, each addressing a specific aspect of the EU’s AML/CFT regime:
1.1. Regulation on Transfers of Funds and Crypto-Assets
Regulation (EU) 2023/1113 (31 May 2023) governs information accompanying transfers of funds and certain crypto-assets.
It becomes directly applicable across the EU on 30 December 2024. By then, the European Banking Authority (EBA) will issue detailed guidelines on implementing restrictive measures for fund and crypto transfers.
1.2. AMLA Regulation
Regulation (EU) 2024/1620 (31 May 2024) establishes the Anti-Money Laundering Agency (AMLA) as the new central authority for AML/CFT supervision in the EU.
The regulation applies from 1 July 2024, with AMLA operations beginning a year later.
1.3. AML Regulation (AMLR)
Regulation (EU) 2024/1624 (31 May 2024) sets out uniform, directly applicable AML/CFT requirements for all Member States.
It will apply from 10 July 2027, harmonizing rules that were previously implemented differently under national laws.
1.4. AML Directive (AMLD6)
Directive (EU) 2024/1640 (31 May 2024) details how Member States must structure their national AML/CFT systems and institutions. It replaces Directive (EU) 2015/849 (AMLD4) and must be transposed into national law by 10 July 2027. AMLD6 also amends the Whistleblower Protection Directive (EU) 2019/1937.
2. Key Reforms and Implications
2.1. A Unified and Expanded AML Regime
The AML Package represents a fundamental overhaul of the existing AMLD4 framework. While AMLD6 and the AMLR significantly expand the scope of obliged entities—including football clubs and agents—they also strengthen obligations on transparency, access to registers, supervision, and enforcement.
By using regulations instead of directives, the EU achieves far greater harmonization of AML rules across Member States.
2.2. Centralized Supervision by AMLA
From January 2028, AMLA will have direct supervisory powers over high-risk financial institutions and indirect oversight over others through national authorities. It may also intervene directly in cases of urgent or cross-border risk. In the non-financial sector, AMLA will coordinate and support national supervisors and Financial Intelligence Units (FIUs), helping streamline reporting and accelerate the analysis of suspicious transactions.
2.3. Development of Technical Standards and Guidance
AMLA will issue binding technical standards, guidelines, and recommendations to obliged entities, supervisors, and FIUs, ensuring consistent interpretation and application of AML rules across the EU.
2.4. Enhanced Harmonization and Legal Certainty
The combination of directly applicable regulations and standardized technical guidance will reduce fragmentation in national AML laws. This creates a more predictable and uniform compliance environment—particularly beneficial for cross-border financial groups operating in multiple EU jurisdictions.
2.5. Stricter Rules for Crypto-Assets and Cash Transactions
Transfers of crypto-assets exceeding EUR 1,000 will face new transparency and traceability requirements. In parallel, cash payments over EUR 10,000 will be prohibited, while transactions between EUR 3,000 and 10,000 will trigger mandatory customer identification.
2.6. Extension of Obliged Entities
Beyond traditional financial institutions, new categories such as football clubs and agents fall under AML obligations. They must implement compliant AML frameworks by 10 July 2029. Certain exemptions will apply, e.g., for non-luxury goods traders.
2.7. Transition to Stricter Enforcement
Even before AMLD6 is fully transposed, regulators are expected to intensify scrutiny under the existing regime. With AMLA’s establishment, a stronger and more coordinated enforcement approach will emerge well ahead of 2027. Obliged entities are therefore advised to use the interim period to review, test, and strengthen their AML controls.
3. Preparing for the New Framework
Obliged entities should begin early alignment with the AML Package. Both the AMLR and AMLD6 already provide a clear view of the final compliance expectations. The AMLR, being a regulation, will apply directly in all Member States, while AMLD6 will define the minimum requirements for national transposition.
To prepare effectively, institutions should:
• Conduct a gap analysis against AMLR and AMLD6 requirements.
• Assess data management, transaction monitoring, and reporting capabilities for alignment with forthcoming technical standards.
• Strengthen governance and documentation frameworks to ensure readiness for AMLA supervision.
• Monitor the development of AMLA guidelines and national transposition laws leading up to 2027.
Although complete clarity will only come once Member States transpose AMLD6 and AMLA issues its technical standards, early preparation can reduce compliance costs and avoid last-minute operational strain.
4. Outlook
The AML Package marks the most comprehensive reform of the EU’s AML/CFT system to date. By introducing uniform rules, centralized supervision, and modernized coverage - including for digital assets and non-traditional sectors - the EU aims to create a consistent and more effective framework to combat financial crime. For obliged entities, the coming years represent a critical window to prepare for stricter oversight, greater transparency, and deeper regulatory integration across Europe.