New EU AML/CFT Framework (2026–2029) – Strategic Analysis and Timeline
LEGAL MEMORANDUM
This memorandum outlines the key innovations and deadlines of the EU anti-money laundering and counter-terrorist financing (AML/CFT) package, adopted in 2024 and implemented between 2026 and 2029. It is addressed to financial institutions and obliged entities to ensure timely preparation and compliance.
I. Legal Framework Adopted in 2024
• Regulation (EU) 2024/1624 (AMLR): establishes a Single Rulebook directly applicable across all Member States.
• Directive (EU) 2024/1640 (AMLD6): sets obligations to be transposed, powers of authorities, and the sanctioning regime.
• Regulation (EU) 2024/1620 establishing AMLA: creates the European Anti-Money Laundering Authority (AMLA), headquartered in Frankfurt.
II. Timeline 2026–2029
• 10 July 2026 – AMLA RTS/ITS (colleges, sanctions, cooperation): Adoption of technical standards detailing cooperation and sanctioning mechanisms.
• H1 2027 – AMLA staff reinforcement (~300): Increased capacity for audits and investigations.
• 10 July 2027 – Application of AMLR + Transposition of AMLD6: Single Rulebook becomes binding; directive fully transposed by Member States.
• End of 2027 – AMLA operational capacity (~430): Start of joint inspections with national authorities.
• January 2028 – Direct AMLA supervision: Direct supervision of ~40 cross-border high-risk financial groups.
• Mid-2028 – BARIS deployment: Full deployment of the Bank Account Registers Interconnection System (BARIS).
• Mid-2029 – AMLA overall evaluation: Evaluation report to the European Parliament and Council.
• End of 2029 – Potential extension of direct supervision: Possibility of expanding beyond the initial 40 supervised entities.
III. Substantive Obligations
• Enhanced CDD/KYC: lower thresholds (EUR 10,000 for occasional transactions; EUR 1,000 for crypto), stricter traceability.
• Transparency & registers: broader access to beneficial ownership registers, 5-year retention, EU-wide interconnection.
• Governance: mandatory AML/CFT officer at executive level, independent audits, annual training.
• Sanctions: up to EUR 10 million or 10% of annual turnover, periodic penalty payments.
• Direct supervision (2028+): inspections, centralized reporting, publication of sanctions.
• Cross-border cooperation: mandatory AML/CFT colleges, information exchange, no obstacles based on professional secrecy.
IV. Strategic Analysis
2026–2027: preparatory phase (gap analysis, updating internal AML policies, anticipating AMLA RTS/ITS).
2027–2028: regulatory shift (AMLR fully applicable, joint inspections, new compliance obligations).
2028–2029: consolidation (direct AMLA supervision, BARIS deployment, evaluation report, possible expansion of scope).
V. Immediate Recommendations
1. Launch internal AML gap analysis by mid-2026.
2. Prepare a 2026–2029 compliance roadmap.
3. Strengthen compliance teams and training.
4. Invest in technological tools (AI, transaction monitoring).
5. Closely follow AMLA technical standards and guidelines.
6. Anticipate direct supervision: adopt an 'AMLA-ready' compliance standard by 2026.
Innocent TWAGIRAMUNGU. Brussels,27.09.2025
