The European Union's comprehensive AML reform package represents the most significant overhaul of anti-money laundering rules in the bloc's history. The Single Rulebook creates directly applicable requirements across all 27 member states, eliminating the fragmentation that has long challenged cross-border compliance.

From Directives to Regulation

Unlike previous AML Directives that required national transposition, the new AML Regulation applies directly in all member states. This means uniform rules on customer due diligence, beneficial ownership, and suspicious transaction reporting across the EU.

Key Changes

The package introduces: harmonized CDD requirements with specific thresholds, unified beneficial ownership rules with 25% threshold, EU-wide cash payment limits of €10,000, enhanced measures for high-net-worth individuals, and specific provisions for crypto-asset service providers.

Timeline

2024: Package adopted
2025: AMLA operational
2027: Regulation fully applicable
2028: Full supervision framework operational

Impact on Group Compliance

For financial groups, the Single Rulebook simplifies cross-border operations. Group-wide policies can now be truly harmonized rather than adapted to each member state's transposition. However, this also means no member state can impose lower standards.

Third Country Provisions

The package strengthens provisions for third-country relationships. Enhanced due diligence requirements will apply to jurisdictions identified as high-risk, with potential countermeasures for the most serious cases.

Preparing for Implementation

Compliance teams should: map current practices against the Regulation's requirements, identify gaps in beneficial ownership procedures, review crypto-asset customer onboarding, and prepare for potential AMLA supervision.