Anti-Money Laundering Authority AMLA

AMLA is a European Union body with its own legal personality, and its seat is in Frankfurt am Main, Germany. Regulation (EU) 2024/1620 establishes it in Article 1, gives it legal personality in Article 3 and fixes the seat in Article 4. Its full name is the Authority for Anti-Money Laundering and Countering the Financing of Terrorism.

The recitals to the regulation explain why it exists. The earlier framework relied heavily on national implementation, and that exposed weaknesses. The answer was a single authority with five kinds of power: direct supervision of a number of selected financial firms, analysis of risks across the internal market, oversight of financial supervisors, oversight of non-financial supervisors, and support for financial intelligence units.

Article 56 gives AMLA a General Board, an Executive Board, a Chair, an Executive Director and an Administrative Board of Review. The General Board sits in two compositions. In each, the Chair and a non-voting Commission representative sit with either the heads of the national supervisory authorities or the heads of the financial intelligence units (Article 57).

AMLA is the authority, not the rulebook. The duties that firms must meet sit in the Anti-Money Laundering Regulation.

Article 5 sets out AMLA's tasks in five groups.

The first group concerns risk across the internal market. AMLA monitors developments inside the EU and in third countries. It also keeps a central database of information received from supervisory authorities and shares its analysis with them.

The second group concerns the firms it supervises itself, which the regulation calls selected obliged entities. The third and fourth concern national supervisors, financial and non-financial. AMLA keeps a list of them, reviews whether they have adequate resources and powers, and works to bring their practices closer together. The fifth group concerns financial intelligence units, the national bodies that receive reports of suspicion from obliged entities.

Beside these sits a rule-making role. Article 6(4) gives AMLA the power to develop draft regulatory and implementing technical standards, to issue guidelines and recommendations, and to give opinions to the European Parliament, the Council and the Commission.

Only credit institutions, financial institutions and groups of them. Article 2 defines a selected obliged entity in those terms, so no other kind of business can be selected.

Selection works in two stages. Under Article 12, AMLA and the national financial supervisors periodically assess institutions and groups that operate in at least six member states. Each one's risk profile is classified as low, medium, substantial or high. Under Article 13, those with a high residual risk profile qualify. If a member state would otherwise have no selected entity, an additional selection process picks one high-risk institution established or registered there.

The dates are fixed in the text. AMLA is to start the first selection process by 1 July 2027 and finish it within six months. It then publishes the list and begins direct supervision six months after publication. Selection is repeated every three years. For the first round, Article 106 changes two things. If more than 40 entities qualify, AMLA supervises the 40 that operate in the highest number of member states. The additional selection for member states with no selected entity does not take place.

Each selected entity is supervised by a joint supervisory team of AMLA staff and staff of the national financial supervisors, coordinated by AMLA (Article 16). AMLA can request information, investigate and inspect premises (Articles 17 to 19). It can order an entity to comply, restrict its business or require changes to its governance (Article 21). These powers apply to selected obliged entities only.

It can also fine. Article 22 sets basic amounts from EUR 100,000 upwards for serious, repeated or systematic breaches. After aggravating and mitigating factors, the ceiling is 10% of total annual turnover for breaches of customer due diligence, internal policies or reporting duties. For breaches of other requirements it is EUR 10,000,000.

In exceptional circumstances, a national financial supervisor may also ask AMLA to take over the supervision of a particular credit or financial institution that was not selected (Article 14).

No. Law firms, notaries, auditors, external accountants and tax advisors stay under national supervision. Auditors, external accountants and tax advisors are obliged entities under the AMLR. So are notaries and lawyers when they take part in the transactions listed in Article 3 of that regulation. None of them is a credit or financial institution, so AMLA cannot select them.

Who supervises them is a matter for each member state. Article 37 of Directive (EU) 2024/1640 requires every member state to appoint one or more supervisors for the obliged entities established on its territory. For two groups it allows a self-regulatory body to do the work in place of a public authority. The first is auditors, external accountants and tax advisors. The second is notaries, lawyers and other independent legal professionals. Where a member state takes that route, Article 52 of the directive requires a public authority to oversee the self-regulatory body.

AMLA's role here is to watch the supervisors. The regulation calls this oversight of the non-financial sector. AMLA carries out periodic peer reviews of non-financial supervisors and of the public authorities that oversee self-regulatory bodies, and publishes the findings (Article 35). Where AMLA suspects that a supervisor or an overseeing authority has not applied EU law, it investigates. It may issue a recommendation within six months. If the breach is not resolved within one month of the recommendation, AMLA issues a warning that sets out the breach (Article 37). It also helps with supervisory colleges for firms established in several member states and mediates between supervisors that disagree (Articles 36 and 38).

None of these powers is aimed at an individual firm. What reaches the firm is the rules. AMLA's guidelines may be addressed to obliged entities as well as to supervisors, and Article 54(3) says that both shall make every effort to comply with them.

The position is open to review. By 31 December 2030 the Commission must report on AMLA's performance. The report must examine whether AMLA should receive additional supervisory tasks for obliged entities in the non-financial sector (Article 102).

AMLA supports and coordinates the financial intelligence units, known as FIUs. It does not replace them. Article 39 makes it responsible for effective and consistent cooperation between FIUs. Reports of suspicion still go to the national FIU, as the AMLR requires.

The main tool is the joint analysis of cross-border cases. An FIU that sees a need to work on a case with FIUs in other member states notifies AMLA. Where AMLA finds the case relevant, it invites the other FIUs within five days. If at least one agrees, AMLA ensures that the analysis is launched within 20 days of its assessment (Article 40).

Three other arrangements support this. Each national FIU delegates one or more staff members to AMLA, and they work at its seat (Article 44). AMLA hosts and maintains FIU.net, the system that FIUs use to exchange information (Article 47). It also runs peer reviews of FIU activities (Article 48), in which FIUs take part voluntarily for the first two rounds (Article 106). It can mediate when FIUs disagree (Article 46).

The regulation keeps this work apart from supervision. AMLA must have dedicated resources for its FIU tasks and, where necessary, separate the staff who do them from its supervisory staff (Article 39(3)).

AMLA produces three kinds of instrument, and the AMLR tells it which ones to write and by when.

Regulatory technical standards and implementing technical standards are drafted by AMLA and adopted by the Commission as regulations or decisions, so they bind. AMLA must normally hold an open public consultation first. The Commission decides within three months of receiving a draft whether to adopt it (Articles 49 and 53). Guidelines and recommendations are issued by AMLA itself. They are not adopted as law, but supervisors and obliged entities shall make every effort to comply, and each supervisor must say within two months whether it complies or intends to (Article 54).

The table lists the instruments under the AMLR that matter most to a professional firm, with the deadline the regulation gave AMLA for each.

Further guidelines are due by 10 July 2027, including on outsourcing (Article 18) and on reliance on customer due diligence carried out by another obliged entity (Article 50). Whether an instrument has been delivered has to be checked against AMLA's own publications.

The regulation has applied since 1 July 2025 (Article 108). It entered into force on 26 June 2024, and the articles that set AMLA up applied from that date. They cover its establishment, its seat, its boards and its power to draft standards and guidelines. One article applied later. The amendments to the European Banking Authority's founding regulation applied from 31 December 2025.

Direct supervision comes later. The first selection must start by 1 July 2027 (Article 13(4)), days before the AMLR itself applies on 10 July 2027. The Commission's first report on AMLA's performance is due by 31 December 2030 (Article 102).