Striding forward

The new EU Anti-Money Laundering Authority (AMLA) continues its progress toward being fully operational. Over the last few months the new authority has made further significant strides, by completing its leadership team, setting out its forward work plans and starting to lay the foundations for supervision of Europe’s most complex and high-impact cross-border financial institutions.

A recent key milestone was the formal appointment of Hennie Verbeek-Kusters as the fifth member of AMLA’s Executive Board. Verbeek-Kusters was nominated to the position in November and confirmed by the European Parliament the following month. On 23 February, EU governments formally approved her appointment: she will take up her post on 1 April. Her appointment (to the position vacated by Marcus Pleyer last summer) brings AMLA’s leadership team to full strength.

A former long-standing head of the Netherlands Financial Intelligence Unit (FIU) and Chair of the Egmont Group of international FIUs, Verbeek-Kusters brings extensive experience in financial intelligence. This is expected to support AMLA in its role coordinating EU FIUs to facilitating intelligence sharing in the fight against cross-border financial crime.

On 4 February AMLA published its first Single Programming Document (SPD), laying out the authority’s priorities and work plans for the coming three years (2026-2028). The SPD (which we discuss in more detail in a separate article here) sets out five interlocking areas of activity including rulemaking, promoting FIU cooperation, preparations for direct and indirect supervision and the development of AMLA’s risk framework. It also includes an ambitious timetable for the formulation of technical standards and guidelines needed to complete the new EU single AML rulebook (which we discuss in a separate article here).

Notably the SPD also articulates AMLA’s technology ambitions: to build cutting edge digital infrastructure for data sharing and analysis. This constitutes a significant and complex IT development project, for which extensive technical expertise will be needed. 

Meanwhile, AMLA continues laying the policy foundations for direct and indirect supervision. EBA conducted a public consultation on two draft RTS setting out its methodologies for assessing the inherent and residual (i.e. after taking account of internal controls) of obliged entities, and for selecting entities for direct supervision from March to June 2025 and incorporated the feedback into its final proposals submitted to the European Commission in October 2025. In December, the authority reviewed these proposals, confirmed they align with its objectives, and adopted them with minor adjustments. Since the substance of the EBA’s proposals remained unchanged and a full public consultation had already been carried out, AMLA did not need to launch a new consultation.

At the start of 2026 AMLA then launched a data collection exercise, to gather information for AMLA to calibrate its risk models. The exercise involves a sample of financial institutions, some likely eligible for direct AMLA supervision, others expected to remain under the ambit of national authorities. The questionnaire, consisting of over two hundred and fifty individual data fields, requests granular information on financial institutions’ customer populations and the nature of their business relationships — as well as their European legal entity structures.

There is now a little over one year before the new EU AML regime, with AMLA at its centre, goes live in July 2027. As its latest actions show, AMLA is pressing ahead with establishing itself as Europe’s central AML regulator and supervisors. Similarly financial and other firms are well advised to ensure their preparations, including gap analyses and subsequent implementation projects, are on track.

By staying informed, firms can position themselves well for success in the rapidly approaching AMLA era. AMLA’s data collection exercise in particular is a potential learning opportunity for firms, to test their systems’ ability to respond to detailed supervisory requests on short time scales. This can support financial firms’ work to identify and implement the changes needed for them to become ‘AMLA ready’.