🎧With the EU AML Package, the European Union is fundamentally reshaping its anti-money laundering framework – both structurally and institutionally. What this means in practice, and why many obliged entities are not yet operationally prepared, is the focus of this episode.
A Systemic Shift in EU Anti-Money Laundering Law
In this episode, which launches our new AML series, host Dana Wondra (Payment & Banking) speaks with Sebastian Glaab, Partner at Annerton, and Dr Camillo Werdich, Founder and CEO of Sinpex, about the transformation of the European AML regime.
At the heart of the reform lies a paradigm shift: the previous directive-based framework, characterised by significant national discretion, will be replaced by a directly applicable AML Regulation. The aim is clear – greater harmonisation and less fragmentation across Member States.
AMLA: A New European Supervisor
A central pillar of the package is the new European Anti-Money Laundering Authority (AMLA), based in Frankfurt. AMLA will directly supervise selected high-risk and cross-border financial institutions.
The reform package also includes enhanced rules on supervisory cooperation and is complemented by the already applicable Funds Transfer Regulation.
Even institutions that remain under national supervision will feel the impact, as supervisory expectations will increasingly be shaped at European level.
The Timeline: 2027 Starts Now
Although the AML Regulation will apply from July 2027, the implementation work starts now.
In the coming years, numerous technical standards and guidelines will define key operational details. Firms must therefore already assess:
- Which processes are affected?
- What additional data requirements will apply?
- How should existing customers be treated?
- Where are the structural gaps?
In practical terms, this means conducting a gap analysis, setting priorities and launching a structured implementation programme – supported by clear governance, adequate resources and proper budgeting.
Market Readiness: A Sobering Picture
Drawing on a Europe-wide readiness survey, Dr Werdich outlines a rather sobering reality.
Only a small proportion of respondents consider themselves well prepared. Many are still in an early assessment phase and have not yet initiated concrete operational measures.
Key challenges include:
- expanded and more granular data requirements
- shorter review cycles
- increasingly complex ownership structures
- the critical importance of audit-proof data
Importantly, “the market” is far from uniform. Large banks are typically familiar with regulatory transformation projects. However, newly captured obliged entities – including certain professional football clubs and agents – are entering AML regulation for the first time.
For them, the transition represents both a burden and an opportunity: those who implement robust and digital structures from the outset can leapfrog legacy inefficiencies and move directly to modern compliance standards.
Conclusion: More Than Just New Rules
The EU AML reform does not merely introduce new substantive obligations. It also marks a clear shift towards more centralised and assertive European supervision.
Firms that focus solely on formal application dates risk finding themselves in costly remediation cycles. Those who act early and strategically can strengthen compliance frameworks while simultaneously improving efficiency and transparency in customer onboarding.
About This Podcast
Alles Legal – Fintech Law in Brief delivers weekly insights into legal and compliance topics in the banking and fintech sectors.
This podcast is a collaboration between Payment & Banking and PayTechLaw.
Each Wednesday, our experts explain current legal developments in a clear and concise way – no legalese, just the context you need. Since 2021, PayTechLaw authors and Annerton lawyers have been bringing legal depth to the mic without losing clarity.
Whether it’s PSD3, DORA or FiDA – we provide the background you need. In 20 minutes. Straight to the point.
