April 2025
AMLA is starting up. The new EU Anti-Money Laundering Authority (AMLA) has been the subject of years of policy debate and legislative effort, since the launch of the EU anti-money laundering (AML) reform package in 2021. Enacted last summer, that legislation formally established AMLA as the centrepiece of the new EU AML regime. Now in the early months of 2025 AMLA has taken a series of important steps towards becoming a fully operational regulator and supervisor.
AMLA’s setup has started from the top. On 22 January, Bruna Szego, former head of AML at the Bank of Italy, was formally appointed as AMLA’s first Chair. This followed detailed scrutiny and confirmation of her nomination by the European Parliament (EP) and EU governments. Szego will now lead AMLA for a four-year term, guiding the new agency through its crucial start-up phase.
Shortly after Szego’s appointment, on 11 March the AMLA General Board (which comprises the AMLA Chair plus the heads of national AML authorities) approved the nomination of five members of AMLA’s Executive Board:
Subject to formal confirmation by MEPs and EU governments, these five Executive Board members should take office in the late spring. This will give AMLA a complete executive leadership, able to decide on the Authority’s priorities, policies and internal organisation.
AMLA has also begun recruiting below executive level and its first policy, legal and administrative staff have started work. In February, staff began moving into Frankfurt’s iconic MesseTurm, chosen last year as AMLA’s headquarters location.
In parallel with AMLA’s start-up, the European Banking Authority (EBA) has begun producing the technical standards to specify details of the new single EU AML rulebook. On 6 March, EBA launched a consultation on four regulatory technical standards on:
Significantly, EBA has proposed a five-year ‘grace period’ before firms must apply new CDD requirements to existing customers. This will allow firms more time to gather the additional information required under the new AML standards. For new customers, EBA proposes the new CDD standards should apply as soon as the new AML rulebook takes effect in 2027.
The EBA has prepared these draft technical standards in support of AMLA. In the coming years, responsibility for producing technical standards will pass from EBA to AMLA, as the new Authority builds up its regulatory capabilities. Existing EBA standards and guidelines will remain in force until superseded by AMLA regulations.
AMLA still has a lot of ground to cover before taking on its full responsibilities. For the rest of this year organisational build-out is expected to be the Authority’s main priority. This will include recruiting an Executive Director (in charge of day-to-day management) as well as more policy and operational staff (AMLA is targeting a total headcount of 80 FTEs by end-2025). Alongside AMLA will set up internal processes and start commissioning the IT and other systems it will need to gather, analyse and share data and coordinate the activities of supervisors and financial intelligence units (FIUs) across Europe.
Once these building blocks are put in place, AMLA’s focus for 2026 and 2027 will then likely shift to further rule-making (in total over 80 technical standards and guidelines must be issued under the new AML legislation), the development of a harmonised European AML supervisory methodology, and preparations for the start of direct supervision in 2028.
This far in advance, it is impossible to predict which 40 firms will be selected for direct AMLA supervision. But it is important to remember that (in contrast with the ECB) AMLA’s supervisory remit extends beyond banks. Insurance and investment firms, asset managers and a range of payment providers also fall within AMLA’s jurisdiction. Indeed, Bruna Szego has herself emphasised this in her first media engagements as Chair and has made a particular effort to reach out to industry associations representing non-bank financial firms early in her tenure. It is likely that when the first cohort of ‘selected obliged entities’ is chosen for direct supervision, AMLA will ensure it includes at least one firm from each of the major sub-sectors beyond banking. In this way AMLA would both assert its prerogatives and build up expertise across the broader financial sector.
AMLA’s start-up steps are a reminder that the countdown to the new AML regime taking effect has well and truly started. Firms should act now to be ready. KPMG professionals recommend the following key actions:
Finally banks should not forget the role of the ECB. Though not an AML supervisor, the ECB coordinates closely with AML authorities, and will be a key partner for AMLA. The ECB also takes account of AML issues in its prudential supervision, for example in its assessment of banks’ governance and internal controls. So banks will need to ensure they can satisfy the expectations of both of the Frankfurt-based EU supervisory authorities.
KPMG’s AMLA Office will provide regular updates and analysis of AMLA strategy, rulemaking and supervisory policy development. KPMG professionals are ready to act to support firms preparing for the new regulatory and supervisory environment and working to become ‘AMLA ready’.
