The new AML package – when will it arrive and what is the status?
The new AML package adopted on May 31, 2024, is a central part of the comprehensive changes being implemented to strengthen the EU's framework against money laundering and terrorist financing. The package mainly includes a new regulation and a new directive. Together, these instruments lay the foundation for the legal framework governing the anti-money laundering and counter-terrorist financing requirements that must be met by operators. In addition, a new authority is being established to harmonize the supervision of the regulatory framework (Amla).
The overall purpose of the new AML package is to modernize and harmonize the EU's anti-money laundering and counter-terrorist financing rules by adopting directly applicable rules across the Union. The regulation will essentially come into force on July 10, 2027. Until then, a number of technical standards and guidelines will be developed by the relevant authorities. Work on this is in its early stages, but a consultation is currently underway on, among other things, technical standards that will specify the information required when implementing KYC processes. However, it should be noted that the Commission has communicated its intention to reduce the number of "non-essential" technical standards and guidelines to Amla by not utilizing all of the authorizations available, in line with the goal of simplifying the regulatory burden within the EU. It remains to be seen which authorizations will not be utilized accordingly.
Below is an overview of a selection of the supplementary regulations that are in the pipeline. Note that the deadline for technical standards refers to the date by which the competent authority must have presented proposals for such standards. Final adoption takes place through a delegated act, which is why the final adoption of technical standards will take place later than indicated below.
Body | Legal instrument | Content | Deadline | Status |
Amla | Technical standards | Information required for the implementation of customer due diligence measures. | July 10, 2026 | Under consultation |
Amla | Guidelines | Aspects to consider when determining the scope of internal rules with due regard to proportionality, with a particular focus on internal control functions. | July 10, 2026 | Not started |
Amla | Guidelines | Minimum requirements for the content of the general risk assessment. | July 10, 2026 | Not started |
Amla | Technical standards | Supervision of groups, e.g. application of group-wide internal rules, exchange of information and identification of parent companies. | July 10, 2026 | Not started |
Amla | Technical standards | Additional measures that in some cases need to be taken with regard to operators' branches and subsidiaries in third countries. | July 10, 2026 | Not started |
Amla | Technical standards | Operators, sectors, and transactions associated with a higher risk. | July 10, 2026 | Not started |
Amla | Guidelines | Risk variables and risk factors to be taken into account when entering into business relationships or carrying out individual transactions. | July 10, 2026 | Not started |
Amla | Guidelines | Ongoing monitoring of business relationships. | July 10, 2026 | Not started |
Commission | Delegated act | Categorization of infringements, degrees of seriousness, and sanctions. | July 10, 2026 | Not started |
Amla | Guidelines | Establishment and management of outsourcing arrangements. | July 10, 2027 | Not started |
Amla & Eba | Guidelines | Measures that may be taken by financial firms to ensure compliance when opening payment accounts with basic features. | July 10, 2027 | Not started |
Amla | Guidelines | Specification of risks, trends, and methods involving geographical areas outside the EU. | July 10, 2027 | Not started |
Amla | Guidelines | Measures to be taken to determine whether a customer holds total assets worth at least EUR 50 million. | July 10, 2027 | Not started |
Amla | Guidelines | Criteria for identifying persons known to be close associates of PEPs and risk levels for PEPs. | July 10, 2027 | Not started |
Amla | Guidelines | Conditions for relying on customer due diligence measures taken by another operator. | July 10, 2027 | Not started |
Amla | Guidelines | Indicators of suspicious activity or behavior. | July 10, 2027 | Not started |
Commission | Delegated act | Lower thresholds for beneficial owners in relation to higher-risk businesses. | July 10, 2029 | Not started |
Amla | Guidelines | Criteria for assessing the suitability of managers and beneficial owners. | July 10, 2029 | Not started |
In addition, the Commission is given a number of powers to adopt delegated acts and implementing acts regarding the classification of high-risk third countries. Furthermore, Member States themselves are given the power to exempt certain operators from the general risk assessment requirements in certain cases and to draw up a list of essential public functions.
It should be noted that although both the Regulation and the Directive are available to operators covered by the AML package, many parts of the package are still outstanding. This makes it difficult for operators to obtain a detailed picture of any gaps in their operations and to plan the resources needed to make the necessary adjustments.
Lindahl is closely monitoring developments and assisting clients with, among other things, conducting gap analyses in relation to the new rules and providing advice on implementation in their operations. If you have any questions about how the new AML package will affect your business, please feel free to contact one of our experts.
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