AMLA / AMLR – the start of a new European supervisory infrastructure



AMLA is indeed the new Anti-Money Laundering Authority in Europe, with the AMLR as the new regulatory framework that will help the European Union fight financial crime. This new EU agency will coordinate national authorities to ensure the correct and consistent application of EU rules. But the establishment of AMLA and the implementation of the AMLR across Europe is so much more than a new regulator, and new AML/CTF rules. 

AMLA is currently building the infrastructure that will continuously test, compare, and challenge firms across the European Union. For the first time, AML/CTF risk management becomes directly comparable at EU level and therefore reputationally and strategically exposed. This implementation links AML KYC activities with several other areas of your organisation, and spans over the full operating model, making this so much more than “just” a Compliance AML/CTF exercise. 

As per Regulation (EU) 2024/1624, of 31st May 2024, AMLA is actively building a framework with 3 pillars, that breaks down the traditional national fragmentation model, and will make AML across Europe harmonised and easier to manage. 
 


Direct EU-level supervision (starting 2028)

AMLA will directly supervise up to ~40 high-risk cross-border financial institutions.
Final selection happens in 2027, Supervision begins in 2028.
Firms will be assessed across jurisdictions, against peers and with a single supervisory lens. AMLA is building a common set of rules for local supervisors, 
that will apply to the entities that will not fall under its direct supervision. 


The Central AML/CFT Database (operational ~2027)

AMLA is creating a central database that will collect: 

  • Supervisory data
  • Risk information
  • Breaches and weaknesses per sector
  • Possibly STR related intelligence flows (via FIUs)

Through this, supervision becomes data-driven, standardised and bench-marked based in a way that we have not seen before. Regulatory
supervision is moving from periodic inspection to continuous data-led oversight, and firms’ AML framework will no longer be judged only 
on its design but on how it performs compared to others. 


FIU coordination and FIU.net

AMLA will strengthen information sharing across the EU, coordinate FIUs and build on the FIU.net infrastructure to make it stronger. This will make intelligence and data flow faster, and cross-border cases will become visible earlier and to a wider audience, at the same time as inconsistencies between jurisdictions will become harder to justify. This will in turn make the European Union as a whole more resilient and a stronger force to reckon with, in the global fight against financial crime and money laundering. 

Through these three pillars, AMLA is transforming AML /CFT from a compliance exercise into a performance-driven supervisory model. Where we have had local supervision, periodic reviews and narrative-based assessments, we will now instead have EU-level oversight, data aggregation and comparability across firms and jurisdictions.


This means that whilst it’s crucial and a regulatory requirement to implement the AMLR and the new RTS’, ITS’ and guidelines by July 2027, it’s an error to treat AMLR as a pure regulatory implementation project. 

Instead, it’s wise and maybe even necessary, to take a wider perspective, and assess the full operating model and redesign it to match the new AML reality. Through the new AML system, AMLA will review end-to-end consistency, with the strong preference of no silos, structured and accessible data that stands for comparison, and scalability across jurisdictions. 

For EU-wide firms with subsidiaries and activities in several EU countries, it will be crucial to ensure consistency across the organisation, for operational frameworks, policies and procedures, outsourcing and oversight. Firms will be required to evidence effectiveness, not just design, of the AML frameworks. 

By preparing your AMLA Target Operating Model (TOM) for AMLA supervision already now, you are ensuring no surprises as AMLA continues to develop and roll out its framework over 2027 and 2028, and you will be in a strong position to capture the full value of harmonisation and simplification across Europe.   

The transition towards a more integrated AML supervisory system represents a fundamental shift for obliged entities across the European Union, and calls for a strategic and forward-looking response that fits the new purpose. Make sure that you see and understand the full scope, and frankly the full potential this shift presents: a golden opportunity to strengthen your framework, enhance the full operating model from A to Z, and break down the silo’s ones and for all. 

By including a full TOM review and upgrade as part of your AMLA/AMLR you can fully capture the scope and significance this new regulatory framework presents, and ensure that your organisation stands ready for the new reality. Simultaneously, this can bring your organisation to the next level, showcasing new organisational possibilities and take operational effectiveness above and beyond.