The establishment of the Anti-Money Laundering Authority (AMLA) marks a new era for financial crime prevention in Europe. Created as part of the EU’s Anti-Money Laundering Package, AMLA has been tasked with driving greater consistency across Member States, strengthening supervisory coordination and supporting a more effective response to money laundering and terrorist financing (ML/TF).
As Europe’s new anti-money laundering framework moves from policy development to practical implementation, the challenge for financial institutions across Europe is no longer simply understanding the direction of travel, but preparing their systems, data and governance for go-live.
For the wider industry, this represents one of the most significant developments in financial crime regulation. Wholesale banks have long operated within a fragmented European AML/CFT landscape, navigating differences in national requirements, supervisory expectations and reporting frameworks.
The new framework seeks to address this through a single rulebook, more harmonised supervision, and greater cooperation and information sharing across the EU. These changes present significant opportunities, but moving from final rules to implementation will also bring practical challenges.
As the focus shifts from rulemaking to implementation, a consistent theme is emerging across the industry: firms support the objective of greater harmonisation and supervisory convergence, but implementation must remain proportionate, risk-based and operationally feasible.
The opportunities
Greater harmonisation should benefit obliged entities operating across multiple jurisdictions. More consistent customer due diligence requirements, greater alignment of supervisory expectations and stronger cross-border cooperation could reduce complexity and support a more level playing field across Europe.
Greater information sharing could also help obliged entities develop a more complete view of financial crime risk across groups and jurisdictions. However, firms will still need to navigate data protection, customer confidentiality requirements and other local restrictions that may limit how customer and transaction information can be shared across borders.
A more harmonised EU framework will not, however, eliminate national differences. National implementation under the Sixth Anti-Money Laundering Directive (AMLD6), including differences in beneficial ownership registers and reporting frameworks, will remain relevant, alongside national risk assessments and local supervisory priorities. The challenge will be achieving greater consistency while maintaining a risk-based and proportionate approach that recognises different business models and risk profiles.
The scale of change also provides an opportunity to address longer-standing issues. As obliged entities review their systems and processes, implementation can support better data quality, reduce manual processes and strengthen links between customer information, risk assessments and monitoring.
Technology will be an important part of this. Automation and artificial intelligence could support customer due diligence, transaction monitoring and beneficial ownership analysis, helping to improve both the efficiency and effectiveness of financial crime controls, subject to appropriate governance and oversight.
The implementation challenges
Timing remains a key challenge. A number of Regulatory Technical Standards (RTS) and guidelines remain under development, but obliged entities cannot wait for complete regulatory certainty before preparing for implementation.
AFME’s industry discussions within its EU AML steering group has highlighted that the changes reach across AML/CFT frameworks, including group-wide information sharing, customer due diligence, ongoing monitoring, suspicious activity reporting, outsourcing and governance. Delivery will, therefore, require coordination across compliance, legal, risk, operations, technology, data and business functions.
Data is another significant challenge. Obliged entities will need to identify critical gaps, strengthen governance and ensure that data can be accessed and used effectively across businesses and jurisdictions.
Beneficial ownership is a particular area of focus. New ownership and control requirements will place additional demands on data, technology and operational processes. Changes to ongoing monitoring will also require a more dynamic understanding of customer risk and stronger links between risk assessments, monitoring and outcomes. For organisations relying on legacy systems or fixed review cycles, this could require significant change.
Preparing for AMLA-led supervision
Implementation is only one part of the transition. Obliged entities must also prepare for a new supervisory environment, with AMLA taking a central role within the EU AML/CFT framework.
Greater supervisory convergence should provide clearer and more consistent expectations across the EU. It is also likely to place greater emphasis on effectiveness and outcomes, with obliged entities expected to show not only that policies and controls are in place, but that they identify and manage financial crime risks effectively.
For international organisations, this reinforces the need for approaches that are consistent at group level while remaining responsive to national requirements, risks and supervisory priorities.
What will readiness look like?
There is no single measure of readiness. Obliged entities will need to understand where the new requirements may result in material change, establish clear ownership and governance, address critical data and technology gaps, and consider operational readiness alongside regulatory change.
Go-live should not be viewed as the end point. The first year of the new regime will test how effectively requirements have been translated into day-to-day processes and whether they deliver the intended outcomes.
AFME continues to work with members on identifying common challenges and engaging with policymakers and supervisors as the detailed requirements develop. As the focus moves towards go-live, this work will continue to support greater clarity, consistency and practical implementation across the industry.
These challenges and opportunities will be at the centre of the From RTS to Go-Live panel at AFME’s inaugural European AML Conference in Frankfurt on 4 November. Bringing together policymakers, supervisors and financial crime leaders, the discussion will explore the road to implementation, preparation for the first year of AMLA-led supervision, and the milestones that will define readiness and success.
