With its formal establishment on 1 July 2025, the European Anti-Money-Laundering Authority (AMLA) has assumed its legal powers and dual mandate as both the European anti-money laundering (AML) supervisory authority and the coordination mechanism for national financial intelligence units (FIUs).
What insights can we draw from AMLA’s first month of operations? Below are selected highlights from KPMG’s AMLA Office, based on the AMLA Work Programme 2025.
Following months of intensive preparations — particularly in recruitment and governance — recent milestones such as the hiring of the permanent Executive Director Nicolas Vasse and the signing of Memoranda of Understanding with the European Central Bank (ECB) and the three European Supervisory Authorities (EBA, ESMA and EIOPA) signal AMLA’s transition from preparation to operational readiness.
While foundational work continues, AMLA’s Work Programme 2025 reflects a clear pivot towards execution, as it looks back on the milestones reached in the first half of 2025 and explains its activities for the second half of the year.
By stating that the crypto-assets market is a high-risk area and ‘an immediate priority’ for AMLA, the authority sets the tone for crypto-asset services providers active in the Union. AMLA expects high standards against financial crime in the crypto sector. In a statement issued on 15 July 2025, AMLA refers to the recent entry into force of the Markets in Crypto-Assets Regulation (MiCA) and the ongoing licensing efforts from national authorities. AMLA notes that “[a]s part of its role in indirect supervision of the financial sector, AMLA expects licencing and supervisory authorities to ensure that CASPs have effective AML/CFT systems in place from day one of their authorisation”.
Although not explicitly stated, AMLA’s Work Programme suggests that the legal deadlines for issuing various technical standards and guidelines may be overly ambitious. The Regulatory Tsunami is approaching yet as AMLA is faced with ‘tight implementation deadlines’ and ‘high expectations’, AMLA warns that its ability to deliver on the policy draft heavily depends on the success of its recruitment process and of the ‘preparatory work delivered by others’ — such as the EBA and its working groups (red.).
AMLA has identified a number of priorities for the policy draft, based on the need to respect the legal deadlines of the instruments, the relevance of requirements for preparing direct supervision by AMLA, the relevance of fostering good cooperation and consistent application of EU standards and the need of AMLA to take over work currently done by others. In relation to its AML/CFT supervisory task, AMLA highlights the following instruments, of which the first two instruments form part of the EBA’s response to the Commission’s Call for Advice (with the public consultation closed in June and the expected final drafts to be submitted by the end of October 2025):
However, it is already clear that the first deadlines for the Regulatory Technical Standards (RTS) on the AMLA Database — set at 27 December 2025 — and Home/Host cooperation between supervisors — set at 10 July 2026 — are at risk. AMLA also warns that the draft Implementing Technical Standards (ITS) on various aspects of cooperation for direct supervision in the European supervisory system will require more time than originally anticipated.
The Work Programme outlines AMLA’s upcoming priorities once more staffing resources are available, and provides further insight into its policy work relating to obligations for obliged entities, such as ongoing monitoring, risk factors, group-wide requirements and the business-wide risk assessment.
For banks, insurers, other financial institutions, crypto-asset service providers and parties from the non-financial sector, the coming months will be shaped by EBA’s response to the Commission’s Call for Advice, especially the draft RTS on Customer Due Diligence (CDD), giving the first direction to the AML Single Rulebook. AMLA’s first public consultations are also expected by the end of 2025.
Based on client conversations throughout 2025, KPMG’s AMLA Office observes varying levels of readiness across the market. It is critical that the private sector proactively prepares for compliance by the 10 July 2027 deadline — even if delays in Level 2 and Level 3 instruments are announced or expected.
And KPMG firms remain committed to supporting clients with insights and guidance as AMLA supervision and the AML Single Rulebook continue to evolve. Our goal is to help you stay on course in your journey to become ‘AMLA ready’.
