The EU’s new AML framework: Unified rules and new supervision
The European Union’s new regulatory framework for combating money laundering and the financing of terrorism (Anti-Money Laundering and Counter-Terrorism Financing, AML/CTF) has been established because of several years of interinstitutional negotiations. The objective of the reform is to harmonize AML regulation, reduce regulatory divergences among Member States, and strengthen cooperation between supervisory authorities.
The new regulatory package is built upon four key legislative acts:
- Regulation (EU) 2024/1620 establishing the European Anti-Money Laundering Authority,
- the new AML Regulation (AMLR – (EU) 2024/1624),
- the 6th AML Directive (AMLD6 – (EU) 2024/1640),
- and the Transfer of Funds Regulation (TFR – (EU) 2023/1113) on information accompanying transfers of funds and crypto-assets.
The package fundamentally reshapes the EU’s AML/CTF system: it introduces a single rulebook, harmonizes national supervisory structures, and establishes the first EU-level AML supervisory authority.
AMLR, AMLD6, and TFR: How are regulations changing?
The central element of the new AML package is the binding AML Regulation (AMLR), which, by virtue of its legal form as a regulation, is directly applicable in all Member States. As part of the so-called Single Rulebook, the AMLR establishes uniform rules for compliance in the field of anti-money laundering and counter-terrorism financing, from which deviation in national legislation is, as a general rule, not permitted.
The Regulation contains detailed provisions, inter alia, on:
- customer due diligence procedures (CDD),
- the identification of beneficial owners,
- internal control systems,
- and restrictions on the use of cash.
The AMLR also significantly expands the scope of obliged entities. In addition to traditional financial institutions, the regulation extends to, for example:
- crowdfunding platforms,
- crypto-asset service providers,
- professional football clubs and agents,
- traders in artworks and cultural goods,
- luxury goods dealers,
- and third-country service providers operating within the EU.
By contrast, AMLD6 is a directive and therefore not directly applicable; it requires transposition by Member States. This allows for greater national discretion, as the directive sets binding objectives while leaving the details of implementation to national legislators. The primary aim of AMLD6 is to harmonize institutional and supervisory frameworks across Member States and to strengthen cooperation among authorities.
AMLD6 specifically regulates:
- the operation of beneficial ownership registers,
- bank account registry systems,
- access to real estate registers for AML purposes,
- the powers of Financial Intelligence Units (FIUs),
- and the competences of national AML supervisory authorities.
In Hungary, the scope of obliged entities for AML prevention continues to be primarily defined by Act LIII of 2017 (the “Pmt.”), and it is expected that a substantial portion of the requirements introduced by AMLD6 will be implemented through this national legislation and sector-specific rules.
The TFR Regulation and the Regulation of Crypto-Assets
The AML package also includes the Transfer of Funds Regulation (TFR), which replaces the previous 2015 regulation on fund transfers.
The new framework extends the so-called “travel rule” to crypto-asset transfers. In essence, service providers are required to transmit information with every transfer concerning:
- the originator,
- and the beneficiary.
The regulation devotes a separate chapter to the obligations of crypto-asset service providers (CASPs) and imposes detailed data reporting requirements on them.
AMLA: The EU’s new central AML authority
One of the most significant elements of the new framework is the European Anti-Money Laundering Authority (AMLA), established by Regulation (EU) 2024/1620.
The Authority will be headquartered in Frankfurt and will commence its operations on 1 July 2025. Direct supervision of high-risk financial institutions is expected to begin in 2028. The designation of high-risk institutions will be determined by AMLA through an iterative selection and review process based on objective risk criteria, relying on data and cooperation from national authorities.
AMLA performs three primary functions:
- Direct supervision of certain financial institutions and crypto-asset service providers presenting high risks of money laundering or terrorist financing.
- Supervisory coordination, aligning and overseeing the activities of national AML/CTF supervisory authorities.
- Support for FIU cooperation, strengthening information exchange and collaboration among Financial Intelligence Units.
An additional key responsibility of AMLA is to support the practical functioning of the unified AML rulebook through various regulatory instruments outlined below.
AMLA Regulatory instruments
AMLA employs several types of regulatory instruments to ensure the consistent operation of the system:
- Regulatory Technical Standards (RTS)
These define detailed technical rules, for example, on risk assessment methodologies, customer due diligence, and supervisory procedures.
- Implementing Technical Standards (ITS)
These establish uniform formats, templates, and procedures for data reporting and supervisory cooperation.
- Guidelines
These provide practical guidance for the design of compliance systems, including areas such as internal controls, risk management, and outsourcing.
- Recommendations
These consist of professional proposals addressed either generally or to specific addresses, aimed at promoting the uniform application of rules.
Addresses of guidelines and recommendations are required to make every effort to comply and must inform AMLA whether they adhere to the provisions set out therein.
What does this mean in practice?
The EU’s new AML package represents the most significant reform in the field of anti-money laundering and counter-terrorism financing regulation in the past decade. The AMLR introduces uniform, directly applicable rules; AMLD6 harmonizes national institutional frameworks; and AMLA assumes a central supervisory role within the EU system. This will affect not only Hungarian legislators but also domestic financial market participants and newly covered entities, bringing substantive changes to their operations.
Full application of the rules will become mandatory from 10 July 2027. Both financial and non-financial obliged entities are advised to begin their compliance preparations, including—where not yet undertaken—assessing and enhancing their technological readiness.
This newsletter constitutes the first part of a series addressing anti-money laundering regulation. Further installments will be published in the coming months, and continued attention to future publications is therefore recommended.
Newsletter prepared by: Evelin Barna and Dávid Vajna
