AMLA Update 

What recent AMLA developments mean for firms 

Since the end of March, AMLA has continued to expand its consultation activities and lay the groundwork for its future supervisory role. While many organisations are focused on upcoming AML Regulation deadlines, AMLA’s recent work provides an early indication of future supervisory expectations.

Focus on governance and risk assessments 

During the past months, AMLA has consulted on group wide AML/CFT policies, procedures and controls, as well as business wide risk assessments. Both topics are fundamental building blocks of the future EU AML framework. 

The message is clear: AMLA expects firms to demonstrate a well documented and risk based approach to AML/CFT compliance, supported by effective governance arrangements and consistent implementation across the organisation. 

For cross-border firms, expectations are increasing around harmonised AML/CFT frameworks and effective group-level oversight.

Supervisory cooperation is becoming more important 

AMLA has also consulted on standards governing cooperation between home and host supervisors for cross border groups. While these proposals primarily address supervisory authorities, they signal a broader move towards greater consistency and coordination across the European Union. 

For firms, this could mean more consistent supervision, greater information sharing and increased scrutiny of cross-border activities.

Preparing for AMLA’s future supervisory role 

AMLA has also published a reporting package to support the future identification of entities subject to direct supervision.

Although direct supervision is not expected until 2028, AMLA is already preparing its supervisory model. This demonstrates that the Authority’s focus is increasingly shifting from institution building towards operational readiness. 

What firms should consider now 

While many organisations are understandably focused on upcoming AML Regulation implementation deadlines, AMLA’s recent work offers an early indication of future supervisory expectations. 

In our view, firms should pay particular attention to the following areas: 

• Reviewing the quality and documentation of business wide risk assessments.
• Assessing whether group wide AML/CFT policies and controls are applied consistently across legal entities andjurisdictions.
• Evaluating governance structures and oversight arrangements to ensure clear accountability for AML/CFT risks.
• Monitoring AMLA consultations and technical standards to identify future implementation requirements at an early stage.

The emerging theme across AMLA’s recent publications is consistency. AMLA’s recent work reflects a clear focus on consistency. The goal is a more harmonised AML/CFT framework across the EU.

As AMLA releases further standards throughout 2026, firms that assess their readiness now will be better prepared for regulatory change.

Compliance Champs will continue to monitor AMLA developments and share practical insights on how firms can prepare for the future EU AML/CFT framework. 

Invitation to Consult

If this article has raised questions or topics you would like to discuss further, we welcome you to reach out. If you have a specific case you would like to explore, we are happy to arrange an informal introductory conversation. Our contact details can be found here.

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