Revolution in AML regulations - 10 key changes introduced by the EU AML Package

After a legislative path lasting almost three years, on 19 June 2024 the acts belonging to the so-called Anti-Money Laundering (“AML”) Package were published in the Official Journal of the European Union. The aim of this article is to answer the following questions:

1. What does the AML Package consist of?
2. How much time do obliged entities have to implement the new AML provisions?
3. What are the 10 most important changes introduced by the AML Package?

What does the AML Package consist of?

The AML Package consists of total of four legal acts:

1. AML Regulation (Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial system for the purpose of money laundering or terrorist financing (OJ. EU. L. of 2024, item 1624);
2. AML Directive (Directive (EU) 2024/1640 of the European Parliament and of the Council of 31 May 2024 on the mechanisms that Member States should put in place to prevent the use of the financial system for the purpose of money laundering or terrorist financing, amending Directive (EU) 2019/1937 and amending and repealing Directive (EU) 2015/849 (OJ EU. L. 2024, item 1640);
3. AMLA Regulation (Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing an Office for the Prevention of Money Laundering and Terrorist Financing and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010 and (EU) No 1095/2010 (OJ EU. L. 2024, item 1620); and
4. Regulation on money transfer information (Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying funds transfers and certain cryptocurrencies and amending Directive (EU) 2015/849 (OJ EU. L. 2023 No. 150, p. 1).

When will the AML Package enter into force?

As for the AML Regulation, the obliged entities have to be compliant with its provisions from 10 July 2027 (except for football agents and professional football clubs, for which the deadline is 2 years longer, i.e. 10 July 2029). It may seem that the 3-year adjustment period is long, but considering the wide range of changes, it is not that much time and it is worth commencing the implementation work as soon as possible.

The AML Directive will enter into force on 9 July 2024 and Member States will be required to implement it to the national legal order in phases, depending on the specific provisions of the act, from 10 July 2027 to a maximum of 10 July 2029.

Regarding the activities of the new supervisory body – Anti-Money Laundering Authority (“AMLA”) will start operating in mid-2025. It will achieve its full powers, including powers in the area of direct supervision, in 2028. Until 31 December 2025, the European Banking Authority (“EBA”) will maintain its powers in the area of AML.

The amended Regulation on money transfer information shall apply from 30 December 2024.

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