The EU’s new AML/CFT package introduces the most significant reforms to the European anti-money laundering framework in decades. This article explores the new legislative framework, the role of AMLA, key implementation milestones and the practical steps financial firms should begin taking today.
The European Union is entering a new era of anti-money laundering and counter-terrorist financing (AML/CFT) regulation. Through a comprehensive legislative package, the EU is moving towards a more harmonised, coordinated and effective framework that will fundamentally reshape how AML/CFT obligations are implemented and supervised across Member States.
The reforms introduce a Single Rulebook, establish the Anti-Money Laundering Authority (AMLA) as the EU’s first central AML supervisor and strengthen cooperation between supervisory authorities across the Union. Although many of the new requirements will not begin to apply until July 2027, the breadth of the changes means firms should begin assessing their governance, customer due diligence, internal controls and compliance frameworks well in advance.
From Fragmentation to Harmonisation
For many years, the EU’s AML/CFT framework relied primarily on Directives, allowing Member States flexibility in how they implemented the legislation into national law. While this approach established a common regulatory foundation, it also resulted in differences in national rules, supervisory practices and enforcement.
For firms operating across multiple jurisdictions, this often meant navigating varying regulatory expectations and inconsistent supervisory approaches.
The new AML/CFT package aims to address these challenges by creating a more integrated and consistent framework across the European Union through:
- Harmonised AML/CFT requirements across Member States;
- Stronger cooperation between national supervisors and Financial Intelligence Units (FIUs);
- Improved transparency and access to key information;
- A new EU-level supervisory authority; and
- A more coordinated approach to AML/CFT supervision and enforcement.
The reforms represent one of the most significant transformations of the EU AML/CFT framework in decades.
The New Legislative Framework at a Glance
The package consists of four key legislative measures, each addressing a different aspect of the EU’s AML/CFT framework.
Legislative Measure | Key Purpose |
AMLAR (Regulation (EU) 2024/1620) | Establishes the Anti-Money Laundering Authority (AMLA), defining its governance, powers and supervisory responsibilities. |
AMLR (Regulation (EU) 2024/1624) | Introduces the EU’s Single Rulebook, harmonising core AML/CFT obligations across Member States. |
AMLD6 (Directive (EU) 2024/1640) | Strengthens national supervision, enhances cooperation between authorities and reinforces the powers of Financial Intelligence Units (FIUs). |
Recast Transfer of Funds Regulation (TFR) | Extends the Travel Rule to certain crypto-asset transfers and introduces new requirements for Crypto-Asset Service Providers (CASPs). |
The legislative framework will also be supported by Regulatory Technical Standards (RTS), Implementing Technical Standards (ITS), Guidelines and Recommendations, providing further detail on how the new requirements should be implemented.
AMLA: A New Supervisory Architecture
One of the most significant developments introduced by the package is the establishment of the Anti-Money Laundering Authority (AMLA).
Operational since July 2025, AMLA has been created to improve consistency in AML/CFT supervision across the European Union. While national competent authorities will continue supervising most obliged entities, AMLA will directly supervise selected high-risk cross-border financial institutions from 2028.
Its responsibilities extend beyond direct supervision and include:
- Coordinating national competent authorities;
- Promoting supervisory convergence across Member States;
- Developing Regulatory Technical Standards (RTS), Implementing Technical Standards (ITS) and guidance;
- Supporting cooperation between Financial Intelligence Units through FIU.net; and
- Exercising enforcement powers over directly supervised entities where appropriate.
The establishment of AMLA reflects the EU’s objective of moving from fragmented national supervision towards a more coordinated and consistent European supervisory model.
Key Implementation Milestones
Implementation of the new framework will take place over several years, providing firms with time to prepare, but also highlighting the importance of starting early.
The key milestones include:
Date | Milestone |
30 December 2024 | The Recast Transfer of Funds Regulation begins to apply. |
1 July 2025 | AMLAR begins to apply and AMLA becomes operational. |
10 July 2027 | AMLR begins to apply and Member States must transpose AMLD6 into national law. |
2028 | AMLA begins direct supervision. |
The phased implementation provides firms with an opportunity to assess the impact of the reforms, prioritise implementation activities and prepare in a structured manner before the new obligations take effect.
What Do These Reforms Mean for Financial Firms?
For financial firms, the reforms extend far beyond legislative change. They will influence governance structures, customer due diligence processes, internal controls, reporting obligations and supervisory engagement, requiring many organisations to review existing operating models and compliance frameworks.
While the detailed operational requirements are introduced primarily through AMLR, the overall direction of the reforms is already clear. Financial institutions should expect increased regulatory expectations across areas including:
- Governance and internal controls;
- Customer due diligence;
- Beneficial ownership identification and verification;
- Reporting obligations;
- Cross-border supervision;
- Group-wide AML/CFT arrangements; and
- Cooperation with supervisory authorities.
Preparing for the New Framework
Although the majority of the new rules will not apply until July 2027, implementation should not be viewed as a last-minute compliance exercise.
As highlighted during our recent webinar (on demand here), organisations should use the transition period proactively rather than waiting for implementation deadlines. Early planning allows firms to identify gaps, prioritise remediation efforts and implement changes in a structured and proportionate manner.
Key actions include:
- Conduct a gap analysis to compare existing AML/CFT frameworks against the new legislative requirements.
- Review policies and procedures, including governance arrangements and business-wide risk assessments.
- Rebuild customer due diligence processes, ensuring onboarding and verification frameworks remain fit for purpose.
- Review monitoring and screening frameworks, including transaction monitoring, sanctions screening and customer review processes.
- Strengthen governance arrangements, including compliance functions, reporting structures and staff training.
- Develop an implementation roadmap, allowing sufficient time to test, remediate and embed the required changes across the organisation.
Early preparation will help firms manage implementation more effectively while reducing operational disruption as the new framework comes into force.
Looking Ahead
The EU’s new AML/CFT package is more than a regulatory update, it represents a fundamental transformation of how AML/CFT will be governed, supervised and applied across the European Union. Through the introduction of the Single Rulebook, the establishment of AMLA and enhanced cooperation between supervisory authorities, the reforms aim to deliver a more harmonised, transparent and effective AML/CFT framework across all Member States.
Organisations that begin preparing now will be better positioned to implement the new requirements efficiently, strengthen their compliance frameworks and navigate the transition with confidence.
Watch our Recent Webinar
For a deeper discussion of AMLR, AMLA and the practical implications of the EU AML Package, watch our recent webinar:
EU’s Latest AML/CTF Package: The Changes Financial Firms Need to Prepare for Now
Presented by Alexandros Constantinou, Senior Managing Director, Complyport EU, the webinar explores the key regulatory changes and the practical steps firms should be taking ahead of the 2027 implementation deadline.
How Complyport Can Help
Preparing for AMLR requires more than simply updating policies. Firms must assess the impact of the new requirements across governance, operations, risk management and compliance functions.
Complyport supports investment firms, payment institutions, electronic money institutions, crypto-asset service providers, fund managers and other regulated firms with:
- AMLR readiness assessments and gap analyses;
- AML governance reviews;
- Compliance function effectiveness reviews;
- AML/CFT framework assessments;
- Board and senior management training;
- Policy and procedure redesign; and
- AMLR implementation programmes.
Our specialists work with firms to assess existing governance arrangements, identify areas requiring enhancement and develop practical implementation plans aligned with the new regulatory requirements.
To discuss how AMLR may affect your governance framework and compliance function, contact Complyport’s regulatory compliance team.
