Clarity On The Implementation Timeline For A Strengthened EU AML/CFT Framework

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Publication of the legislative texts constituting the EU's new AML/CFT framework provides clarity on the implementation timeline for supervised entities.
European Union Government, Public Sector
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Publication of the legislative texts constituting the EU's new AML/CFT framework provides clarity on the implementation timeline for supervised entities. While the new and stricter framework will largely start applying as from 10 July 2027, AMLA, the new Authority for Anti-Money Laundering and Countering the Financing of Terrorism, will already begin its work on 1 July 2025.

On 19 June 2024, Regulation (EU) 2024/1620 establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA Regulation), Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLR) and Directive (EU) 2024/1640 on the mechanisms to be put in place by Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLD6) were published in the Official Journal of the EU.

With the publication of these texts, the EU is setting out new and stricter rules and as such is strengthening the EU's systems in the fight against money laundering and terrorist financing. For a summary of the new regime, read our newsflash 'The new AML/CFT package finally adopted by the EU Parliament' from 14 May 2024.

Entry into force and application

The new EU AML/CFT framework will apply as follows:

  • The AMLA Regulation will enter into force on 26 June 2024 and will start to apply on 1 July 2025 (with the exception of certain Articles). For a summary of the new Regulation, read our newsflash 'AMLA: a new game-changer at institutional level'.
  • The AMLR will enter into force on 9 July 2024 and will apply as of 10 July 2027, with the exception of the rules concerning certain professional football clubs and football agents, which will apply as of 10 July 2029. For a summary of the new Regulation, read our newsflash 'AMLR: a new EU-wide level playing field through increased harmonisation'.
  • AMLD6 must be implemented by Member States by 10 July 2027 at the latest. However, the rules concerning amendments to Directive (EU) 2015/849, also known as AMLD4, must be put in place by 10 July 2025 and the rules concerning beneficial ownership by 10 July 2026. The single access point to real estate information must be implemented by 10 July 2029. AMLD4 will be repealed with effect as from 10 July 2027. For a summary of AMLD6, read our newsflash 'AMLD6 – EU unveils tougher anti-money laundering rules: key highlights'.

The EU Commission must submit a report to the EU Parliament and to the Council of the EU on the implementation of AMLD6 and the application of the AMLR by 10 July 2032 and every three years thereafter.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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