Key dates
- March 6, 2025
- EBA consultation launch; on draft RTS for AML/CFT standards (ongoing as of analysis)
- January 1, 2026
- EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA; ; existing EBA guidelines remain until replaced
- July 10, 2027 Deadline
- New AMLD6/AMLR rules apply directly; , including CDD for new customers and start of phased compliance
- 2028
- AMLA begins direct supervision; of selected high-risk entities
- By July 2032 Deadline
- Full CDD compliance; for existing customers (five-year transition from 2027)
Suggested considerations
- Participate in EBA consultation: Submit feedback on draft RTS via EBA channels, focusing on risk indicators, data frequency, and feasibility; AMF encourages French firms to act promptly.
- Conduct compliance gap analysis: Review current AML frameworks against proposed indicators (inherent risk, controls, residual risk); prioritize high-risk customers/products.
- Enhance systems: Invest in regtech for automated risk scoring, transaction monitoring, and data reporting to supervisors; update governance, policies, and CDD processes.
- Prepare for AMLA supervision: For cross-border firms, model group-wide risk profiles; develop remediation plans for breaches.
- Ongoing monitoring: Implement annual risk reviews and ad-hoc reassessments for business changes.
What changed
- The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
- Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control...
- Risk Assessment for Direct Supervision (Article 12(7) AMLAR): Two-stage selection for AMLA direct oversight of high-risk cross-border firms (operating in ≥6 Member States, meeting...
- CDD Updates: Risk-based approach for new customers from July 2027; five-year transition for existing customers, prioritizing high-risk.
- Pecuniary Sanctions RTS (Article 53(10) AMLD6): Structured classification of breaches, proportionate sanctions, and enforcement for serious/repeated/systematic infringements to ensure uniformity...
Compliance impact
Urgency: High – While not yet final, the consultation shapes binding RTS under the new AMLA-led regime post-January 2026 handover, with direct rules from July 2027 requiring system upgrades and data readiness; delays risk non-compliance with harmonized supervision, higher sanctions, and AMLA scrutiny for large firms. Matters due to shift to uniform EU standards, ending national discretion and increasing reporting burdens—firms acting now can influence outcomes and future-proof via tech/governance investments.