The European Union is overhauling its Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) framework. With the adoption of the EU AML legislative package, including Regulation (EU) 2024/1624 (the Anti-Money Laundering Regulation – AMLR), the EU aims to establish a more harmonised, consistent and effective approach to combating financial crime across all Member States.
The new AML Rulebook will become applicable on 10 July 2027, as a regulation, it will apply directly in all Member States, without national transposition.
Who will be affected?
The new framework will directly affect a broad range of obliged entities, including:
- Banks, financial institutions and payment service providers.
- Crypto-asset service providers.
- Accountants, auditors, tax advisors and certain legal professionals.
- Trust and Company Service Providers (TCSPs).
- Real estate agents and other property-related professionals.
- Gambling service providers and certain traders in high-value goods.
The precise obligations will depend on the nature of each entity’s activities and its classification under the Regulation. Certain sectors, including football clubs and agents, will become subject to the relevant AMLR requirements from 10 July 2029.
What are the key changes?
The new AML Rulebook introduces a more consistent set of requirements across the EU, reducing differences between national AML frameworks.
Among the most significant changes are:
1. Stricter Customer Due Diligence (CDD)
Businesses will need to strengthen their customer identification and verification procedures, beneficial ownership checks, understanding of ownership and control structures, and ongoing monitoring of business relationships. They will also need to be able to evidence these checks to supervisors.
2. Risk-Based Approach
Companies will need to ensure that their AML risk assessments adequately reflect customer, geographical, product, service and transactional risks, with appropriate enhanced due diligence measures applied to higher-risk relationships.
3. Stronger Internal Governance
The framework reinforces the importance of management oversight, clearly defined responsibilities, effective internal controls, staff training and documented AML procedures.
4. Increased Transparency and Monitoring
Greater attention will be given to beneficial ownership information, politically exposed persons (PEPs), suspicious transactions, record-keeping and compliance monitoring.
5. Greater Supervisory Convergence
The establishment of the European Anti-Money Laundering Authority (AMLA) will strengthen coordination between national supervisory authorities and promote consistent application of AML/CFT requirements across the EU.
How should companies prepare?
Businesses should not wait until July 2027 to address the upcoming changes. Preparation should begin with a comprehensive review of existing AML policies, procedures and internal controls.
Companies should consider conducting a regulatory gap analysis, updating their risk assessment methodologies, reviewing customer onboarding and due diligence processes, strengthening transaction monitoring arrangements and ensuring that employees receive appropriate AML training. Companies should also check whether existing compliance resources, systems and procedures are sufficient to meet the new regulatory expectations.
Eurofast’s Take
Eurofast can support businesses with regulatory gap assessments, AML policies and procedures, risk assessment reviews and staff training ahead of 10 July 2027. For businesses without an in-house compliance function, we can also provide outsourced compliance support to set up and maintain a framework that meets the new requirements.
For more information or personalized assistance, please contact Ekaterina Demina at [email protected]