Countdown to AMLAR compliance: the EBA’s draft technical standards

The initial four draft standards, which were developed in response to mandates from the newly established Anti-Money Laundering Authority (AMLA), represent a significant shift in Europe’s AML framework, defining how risk is assessed, how institutions will be supervised, how customer due diligence is applied, and how enforcement is carried out.  

As the public consultation period nears its close, now is the time for firms to review their current AML framework aligns with the proposed requirements and prepare for the transformation journey towards the 2027 implementation.
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What Is AMLAR? A New Chapter in AML Supervision

Formally established in 2024 and headquartered in Frankfurt, AMLA, the European Anti-Money Laundering and Countering the Financing of Terrorism Authority, is the cornerstone of the EU’s new AML package. Its creation marks a pivotal evolution in efforts to combat money laundering and counter terrorist financing, to unify the AML framework and previous fragmented implementation across the EU member states. Learn more about AMLAR here.
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A reminder on AMLAR's mandate:

• Direct supervision of a possible 40 obliged entities. Higher-risk profile credit and financial institutions, including crypto service providers. The first obliged entities selected for direct supervision have not been publicly named, expected to be selected during 2027.  

• Coordinating and supporting national Financial Intelligence Units (FIUs) to ensure cross-border collaboration and faster investigations. One key tool being used here is advanced data analytics from a single common information system.

• Implementing and enforcing a single AML rulebook, bringing consistency and clarity to compliance requirements across all EU member states. The first four draft RTS, previously mentioned, are currently in circulation in this regard.  
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In a keynote at the European Anti-Financial Crime Summit in Dublin on the 7^th of May Bruna Szego, AMLA’s inaugural Chair, underscored the Authority’s vision which aims to create a robust, intelligence led AML regime anchored in cooperation, transparency, and accountability for all members. Her message was clear “Our timeline is tight, and the issues we face are many. We must act with determination.”

The Delta Capita team was on the ground at the European Anti-Financial Crime Summit in Dublin, engaging directly with regulators, industry leaders, and AMLA representatives. We connected and captured the pulse of what’s next in financial crime compliance. Read our insights here.
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The Draft RTS in Focus: Redefining AML Compliance

Published by the EBA on the 6^th of March earlier this year, the public consultation paper contains initial set of technical standards that translate legislative intent into actionable compliance obligations and guidelines across four critical areas:
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1. Risk Assessment

Draft RTS under Article 40(2) of AMLD6 on the assessment of the risk profile of obliged entities

Sets standards for assessing the inherent and residual risk profile of financial institutions and ensuring consistent AML/CFT supervision across the EU.
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2. Direct Supervision

Draft RTS under Article 12(7) of AMLAR on the risk assessment for the purpose of selection of credit institutions, financial institutions and groups of credit and financial institutions for direct supervision

Establishes criteria for selecting entities subject to AMLA’s direct oversight.
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3. Customer Due Diligence (CDD)

Draft RTS under Article 28(1) of AMLR on Customer Due Diligence

Defines requirements and standardised approach for risk-based CDD, beneficial ownership and Politically Exposed Persons (PEPs). Key requirements include:

• The uniform collection of data across member states

• Embedding of standards for simplified and enhanced due diligence for consistency  

• Reinforcement of the use of central registers and reliable independent sources  

• Mandatory screening and ongoing monitoring requirements  

From 2027, all new customers will have these new rules applied, a five-year transition period is expected to update all existing customer relationships.

4. Enforcement and Compliance

Draft RTS under Article 53(10) of AMLD6 on pecuniary sanctions, administrative measures and periodic penalty payments

Introduces a unified enforcement regime across the EU. Institutions that fall short of compliance can expect a range of consequences including financial penalties, administrative sanctions, and recurring fines which will be calibrated to the severity, intent, and impact of the breach.

What was once considered “best practice” will now be mandatory. Non-compliance won’t just mean reputational damage but could mean real financial and operational consequences. A structured appeals process will be in place, but the messaging is clear: enforcement is no longer optional, and the bar has been raised.

This is just the first wave, further RTS are anticipated throughout 2025 and 2026 as part of a phased regulatory rollout. Stay tuned for additional developments as AMLA gears up for full implementation.

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AMLA Supervisory and Technical Standards Timeline

What’s next?

EU financial institutions have been operating under a fragmented AML regime. While iterations of overarching directives like AMLD5 and AMLD6 provided a framework, implementation was left largely to national discretion which led to issues such as inconsistent supervision and enforcement across member states, divergent risk assessment models and CDD standards and limited coordination between national FIUs.

As the public consultation on the first draft standards closes in the coming week, EU institutions stand at a critical milestone. The feedback gathered will help shape the AML rulebook and with it, the supervisory expectations and compliance obligations that institutions must meet.

Now is the time for firms to proactively assess their current frameworks, identify gaps, and begin planning for the coming operational change. Post-consultation, we can expect regulatory finalisation and clearer enforcement timelines, particularly as AMLA gears up for full operational status. Institutions that act early will be best positioned to manage the transition effectively.

How DC can help

At Delta Capita, we understand the complexity of navigating evolving regulations and the operational demands of Client Lifecycle Management (CLM). Our CLM Health Check is designed to give you a rapid, independent assessment of your current onboarding and compliance landscape helping you validate assumptions, identify gaps, and shape a clear path forward.

Whether you're preparing for AMLA compliance or looking to optimise your KYC and onboarding processes, our experts are here to support you. We combine deep regulatory insight with hands on delivery experience to help financial institutions streamline operations, reduce risk, and enhance client experience.

Explore how our CLM Health Check and Regulatory Hub can help you stay ahead of regulatory change and unlock operational value. Reach out to our team of CLM and change experts today.

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