How are you handling the new EU AML Authority (AMLA) requirements?

With AMLA becoming operational, I'm trying to understand the practical impact on our compliance program. We're an EU-based payment institution operating across 6 member states.

Specific questions:

• Has anyone started mapping their current program against the anticipated AMLA direct supervision requirements?
• How are you handling the transition from national FIU coordination to the centralized AMLA approach?
• Any guidance on what the "directly supervised entities" criteria will look like in practice?

Would love to hear from others who are preparing for this.

Something to consider: even if you're not in the first wave of direct supervision, AMLA will set supervisory standards that national supervisors must follow. So indirectly, everyone's exam experience will change.

We've started building a crosswalk between our current national requirements and the draft AMLA regulation to identify gaps early. The biggest area of change for us is beneficial ownership — the requirements are becoming much more prescriptive.

The practical impact of AMLA depends a lot on your institution's footprint. For firms operating in multiple EU member states, the centralized supervisory approach should eventually simplify things — instead of navigating different national interpretations, you'll have one authority setting the standard.

But the transition period is going to be messy. AMLA won't have full supervisory authority until 2028, and in the meantime national regulators still run the show. Our recommendation:

Map your current obligations — Document what each national regulator currently requires. This becomes your baseline for understanding what AMLA might change.

Watch the rulemaking — AMLA is expected to issue binding technical standards that will standardize CDD requirements, transaction monitoring expectations, and reporting formats across the EU. Stay close to the consultation process.

Budget for systems changes — Standardized reporting formats will likely require updates to your AML systems, particularly SAR filing workflows. Build this into your 2027-2028 IT budget now.

The single rulebook concept is good in theory. Whether AMLA can actually harmonize 27 national approaches remains to be seen, but the direction of travel is clear.