AMLA is here… Now what?

October 2024

It’s official: AMLA is here

AMLA officially arrived in July. On 19 July, the Regulation establishing the new EU Anti-Money Laundering Authority (AMLA) was published in the EU Official Journal, completing its long journey to the statute book. Seven days later, the legislation took effect and the agency at the heart of the new EU-wide AML regime formally came into being.

In parallel, the AML Regulation — creating the new single AML Rulebook — was also published and took effect. The three-year countdown until the new rules enter force (to be supplemented by AMLA technical standards and guidelines) has thus started.

Starting up AMLA

The AMLA’s first months will be focused on institution building. Before the new agency can begin making regulations or defining supervisory policy it must first recruit key decision-makers and build up its operational infrastructure.

This process will be led by the European Commission (EC) AMLA Task Force. This special unit within the EC’s financial crime division has been developing practical plans for the new agency (covering everything from IT systems to business processes) while the AMLA Regulation worked its way through the legislative process. The Task Force will now act as a skeleton crew for AMLA in its initial start-up phase.

Appointing the leaders

The immediate priority is to appoint the AMLA’s leadership. The EC has already begun this process by advertising the position of Chair in June. The aim is to have AMLA’s first Chair in place around the end of 2024, with the five Executive Board members (the EC advertised these positions on 2 September) following in the first quarter of 2025.

This, however, is an ambitious objective given the elaborate appointment process set out in the AMLA Regulation. For the Chair, this specifies that the EC must propose a shortlist of at least two candidates, who may then be called for scrutiny hearings before the European Parliament (EP). Having had EP feedback, the EC will then nominate an AMLA Chair, who must be confirmed by both the EP (likely after a further hearing, and both committee and plenary votes) and EU governments before taking up the post. Given that the EP must first confirm a new EC Chair following June’s European elections, it remains to be seen whether an AMLA Chair can be appointed before the end of the year.

Beginning operations

Once the AMLA executive team is in place, it will be able to decide how the new agency is organised and managed. The EC plans for the AMLA to begin operations in mid-2025, focusing initially on establishing internal structures and systems.

After this, the EC expects the AMLA to begin consulting on implementing rules to complete the new single AML Rulebook in 2026. As we have previously written, working groups coordinated by the European Banking Authority (EBA) have already begun informal work on multiple draft guidelines and technical standards. Once the AMLA has built up its policy-development capability (which could include hiring some current EBA staff), the new agency will take over the task of finalising these regulations.

Getting ready for the AMLA

Fighting financial crime is a marathon not a sprint, and the AMLA looks set for a measured start. With the rules it makes applying from mid-2027, and direct AMLA supervision beginning in 2028, regulated firms may be tempted to think there is little need to act now. In our view, that would be a mistake. The new AML Rulebook will require significant changes to firms’ internal controls, and the new EU-wide supervisory methodology AMLA will develop will have a major impact on how compliance is overseen. AMLA’s early months will provide important indications of its policy approach, as well as offering opportunities for the industry to engage with the new agency and share expertise.

In the months ahead, firms should review their existing AML practices against the new rules and closely monitor the AMLA’s first steps. KPMG’s AMLA Office will provide regular updates and analysis of the AMLA’s strategy, rulemaking and supervisory policy development. KPMG professionals are ready to support firms preparing for the new AML environment and working to become ‘AMLA ready’.