The failure of Dublin’s 2024 bid for the EU’s new Anti-Money Laundering Authority (AMLA) – now based in Frankfurt and officially opened in July – may have rankled, but there is little time for hard feelings as the world ‘confronts a financial crime epidemic’ in the words of Stephanie Champion, head of fintech Nasdaq Verafin.
The Canadian company says that over US$3 trillion in illicit funds was in circulation globally in 2023, while its 2025 survey found just 22% of financial crime specialists were confident that they have the resources to do their work.
Step change
The arrival of AMLA heralds a step change in anti-money laundering and countering the financing of terrorism (AML/CFT), and the new body can boast a first in being a central EU authority with direct and indirect supervisory roles among national authorities in AML/CFT and a lead in the development of technical standards.
‘Football agents and professional football clubs will need to comply with AML requirements’
It also opens its doors supported by a potent new package of AML measures. Sinead Ovenden, a partner at PwC Ireland, describes this raft of regulations and directives from the European Commission (see ‘Key measures’) as ‘a unified and far-reaching framework to combat money laundering (ML) and terrorist financing’ that collectively aims ‘to create a cohesive, risk-based and technology-enabled AML/CFT regime across the EU’.
Key measures
The EU’s new package of anti-money laundering measures includes the following:
- Regulation (EU) 2024/1620. Establishes the Anti-Money Laundering Authority and its supervisory powers, with its headquarters in Frankfurt. A central database will enhance transparency and information sharing at national and EU level.
- Regulation (EU) 2024/1624. Introduces the Single Rulebook, replacing fragmented national rules with directly applicable EU law. General application commences in July 2027 with sector-specific provisions from July 2029.
- Directive (EU) 2024/1640: Sixth Anti-Money Laundering Directive (AMLD6). This directive complements the Single Rulebook by reinforcing national supervisory capacity and inter-agency cooperation. Enhances national supervisory mechanisms and cooperation. Must be transposed into national law by member states by 10 July 2027.
- Directive (EU) 2024/1654: Centralised Bank Account Registries. Expands access to centralised bank account registries for law enforcement.
Source: PwC
Broader scope
The central place of the AMLA in this new framework is worth reiterating. While the standard member state transposition of AML regulations into national laws ‘comes with the risk of incomplete or limited harmonisation’, as Melvin Tjon Akon of DLA Piper puts it, the existence of the AMLA provides ‘for a more uniform approach than in the past’.
Key among its safeguards is the direct role for the AMLA in supervising ‘high-risk’ financial institutions and obliged entities, particularly those that have a presence in multiple member states – although the specifics of this have yet to be announced.
A new vigour in supervision and crossborder alignment is further supported by an expansion in scope, with AML/CFT requirements set to apply for the first time to professional football clubs and traders of high-value goods. The rational for the former was set out in a 2022 European Commission report that found ‘sport has been used by criminals to launder money and derive illegal income. Football, being by far the most popular sport in the world, is an obvious candidate.’
Jeffrey Greenbaum, a partner at Hogan Lovells, says ‘football agents and professional football clubs will be required, among other things, to comply with AML requirements’ and ‘in particular, to report suspicious transactions to the competent financial intelligence units’.
‘The new regime is nothing short of a revolution in EU financial services law’
The direct impact of this on Irish sport is, as yet, hard to quantify. These particular regulations will not come into effect until 2029 and member states may exempt clubs with annual turnover under €5m. A 2023 BDO Ireland report found the combined turnover of League of Ireland clubs in 2023 to be €38.1m.
More clearcut is the inclusion of crypto-asset service providers, crowdfunding services and those selling high-value goods. Examples of the latter include traders of jewellery and watches valued at €10,000 plus, vehicles exceeding €250,000 and aircraft and boats with a price tag of €7,500,000 or more.
‘Not feasible overnight’
In May, the government published its updated AML workplan and said that ‘work on the necessary transposing legislation is underway by the Departments of Finance and Justice’. Accountancy Europe’s advice for finance professionals can be summed up as ‘start preparations early’. It says the new measures ‘impose significant responsibilities, and their implementation is not feasible overnight. This is especially important for smaller practitioners, who will need to thoroughly review AML compliance for each of their new and existing clients’. (See ‘Advice for practitioners’.)
‘What does direct supervision mean compared to member state supervision?’
Advanced planning is the watchword across the financial services sector. Sébastien Praicheux, a partner at Norton Rose Fulbright, says that ‘The new regime is nothing short of a revolution in EU financial services law with direct AML/CFT regulation across the entire financial services sector for the first time’. His advice for larger institutions is that ‘where direct supervision by the AMLA is a real prospect, the key question for the moment is what does direct supervision exactly mean when compared to member state supervision?’
Advice for practitioners
Map compliance gaps. Align existing policies and procedures with the updated standards.
Futureproof your governance model. Increased obligations and accountability for senior management will reshape responsibilities.
Reinforce your compliance culture. Move on from a pure tick-the-box mentality.
Examine underlying processes. Evaluate and strengthen processes such as identifying beneficial ownership.
Pay attention to detailed changes.
Prioritise data security. The new rules impose significant obligations for client data collection.
Ensure a consistent approach across firms and networks.
Assess whether your firm structure falls under the provisions in Article 16. By 10 July 2026, regulatory technical standards will define the minimum requirements for group-wide policies, procedures and controls.
Educate and inform your clients.
Use the AMLA guidelines.
Relay feedback to the AMLA.
Collaborate with professional bodies.
Source: Accountancy Europe
The push for change
The litmus test for the AMLA will be its impact on those dizzying ML figures, which have so far proved hard to address. A decade ago, Europol research put the asset recovery rate in Europe for ML at 1.1%, based on data for the period 2010-14. This year’s Europol assessment notes: ‘Despite substantial investments in resources and legislative frameworks, the confiscation of criminal proceeds has stagnated at around an estimated 2% of illicit proceeds.’
Not everyone is convinced that the AMLA can deliver. Karel Lannoo, CEO of the Centre for European Policy Studies, has argued that action on AML/CFT ‘requires more harmonisation of judicial procedures and criminal offences, which EU member states have so far been unwilling to do’.
Finance may be central but it’s not the only metric to judge success; other issues speak equally to our uncertain times. Lannoo argues that where ML activity prospers, ‘Crime proliferates, citizens see that rule of law does not work and the foundation of civil societies is degraded.’
