Anti Money Laundering / Countering Financing of Terrorism

The EU’s approach to anti-money laundering and counter-terrorist financing (“AML/CFT”) is undergoing its most fundamental overhaul since the first EU AML Directive was adopted over three decades ago.

The new EU AML/CFT reform package will introduce the following four main legislative instruments for the purpose of strengthening EU-wide AML/CFT rules and harmonising requirements across all EU Member States:

The EU Single Rulebook — Regulation (EU) 2024/1624 (AMLR), this directly applicable regulation sets harmonised AML/CFT requirements binding on all obliged entities from 10 July 2027.
The Sixth AML Directive — Directive (EU) 2024/1640 (AMLD6), establishes the national institutional and supervisory frameworks that Member States must put in place, including the powers and responsibilities of national supervisors, financial intelligence units, and the applicable sanctions regime. Member States must transpose the majority of AMLD6 by 10 July 2027, with certain provisions — including those governing the AML/CFT compliance officer and management body responsibilities — transposable from 10 July 2026.
The AMLA Regulation — Regulation (EU) 2024/1620 (AMLAR), establishes AMLA as the new central EU authority for AML/CFT with responsibility for directly supervising certain high-risk financial entities, coordinating national supervisors across both financial and non-financial sectors, supporting financial intelligence unit cooperation, and developing the technical standards and guidelines that underpin the new framework.
The Transfer of Funds Regulation — Regulation (EU) 2023/1113 (ToFR), which recasts the existing regulation on the transmission of information accompanying transfers of funds and extends its scope to transfers of crypto-assets handled by crypto-asset service providers. This regulation has applied since 30 December 2024.

The Authority for Anti-Money Laundering and Countering the Financing of Terrorism (“AMLA”)

AMLA assumed its principal powers and commenced operations on 1 July 2025. On 31 December 2025, the EBA’s standalone AML/CFT mandate – which it had held since 2020 – was formally transferred to AMLA, establishing AMLA as the sole central body responsible for developing the programme of regulatory technical standards (“RTS“) and implementing technical standards (“ITS“) that give the Single Rulebook its operational content. Existing EBA AML/CFT guidelines and technical standards remain in force in the interim.

AMLA’s mandate includes:

directly supervising certain financial sector obliged entities deemed to present a higher risk of money laundering or terrorist financing (including the imposition of sanctions where warranted);
coordinating indirect supervision of obliged entities across both the financial and non-financial sectors;
supporting and coordinating financial intelligence units across the EU;
developing and maintaining a European AML/CFT database on risks and breaches; and
producing regulatory and implementing technical standards and guidelines.

AMLA has moved quickly since assuming its mandate. It has already issued final draft RTS on the methodology for selecting obliged entities for direct supervision and on the assessment of entity-level ML/TF risk profiles.

AMLA has conducted multiple public consultations in 2026 covering customer due diligence, group-wide requirements, pecuniary sanctions, and ongoing monitoring of business relationships, among others.

A substantial cluster of 19 RTS, ITS and guidelines is due for submission to the European Commission by 10 July 2026. Direct supervision of selected high-risk financial entities is expected to commence in the course of 2028.