The EU’s 2025 AML Package: What It Means for Compliance, Governance and the Future of Financial Supervision

A New Era for Anti-Money Laundering in the EU

April 24, 2025

Dr. Philipp Eska

Introduction: A New Era for Anti-Money Laundering in the EU

In 2024, the European Union adopted its most ambitious and far-reaching set of Anti-Money Laundering (AML) measures yet — collectively referred to as the new AML Package. Designed to create a uniform and robust AML/CFT framework across the EU, this package introduces a blend of new rules, a central supervisory authority and stricter expectations for businesses operating in high-risk sectors.

With full implementation beginning in July 2027 and direct EU-level supervision starting in 2028, companies across the financial and non-financial sectors are now on the clock. Whether you're a bank, a fintech company or a professional services firm—this legislation will reshape how you handle customer onboarding, due diligence and reporting obligations.

Why a New AML Package?

Despite several iterations of the AML Directive over the years, inconsistencies in enforcement and supervision have persisted across EU Member States. This has created regulatory gaps, uneven compliance burdens and opportunities for criminals to exploit national differences in enforcement.

The new AML Package aims to solve this by:

Harmonizing rules across the EU
Introducing binding regulations alongside directives
Establishing the new Anti-Money Laundering Authority (AMLA) for direct supervision

This marks a shift from a fragmented framework to a centralized, enforcement-focused system that emphasizes both prevention and punishment.

What’s Inside the AML Package?

The AML Package is made up of several key legal instruments, including:

Revised 6th AML Directive
New AML Regulation (AMLR)
Regulation establishing the AML Authority (AMLA)
Regulatory Technical Standards (RTS) on Customer Due Diligence (released in draft form in March 2025)

Each of these plays a specific role in creating a cohesive system for risk-based supervision, enforcement and data-driven compliance.

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A New Supervisory Authority: AMLA

One of the most significant changes is the creation of AMLA – the Anti-Money Laundering Authority, headquartered in Frankfurt. AMLA is set to be a game-changer in the EU's financial oversight.

By 2028, AMLA will directly supervise 40 high-risk entities and coordinate with national authorities. This body will:

Ensure consistent application of AML rules across all EU states
Develop common supervisory methodologies
Act as a direct interlocutor for large cross-border institutions
Enhance the exchange of best practices and feedback loops between entities and regulators

This consistency will help eliminate the “supervisory arbitrage” previously seen when companies received conflicting guidance from national regulators.

Key Dates and Timeline

Understanding the timeline is crucial for preparation and compliance planning.

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New Requirements: What Changes for Companies?

The AML Package doesn't just aim for consistency—it also raises the bar for compliance across the board. Some of the most impactful updates include:

Higher KYC Standards

Customer Due Diligence is being standardized EU-wide, with stricter obligations such as:

Collecting place of birth and dual nationality, not just date of birth
Verifying occupation or profession to clarify the “nature and purpose” of a relationship
Ensuring that eID (electronic identification) is used for remote onboarding, with only those meeting Substantial or High assurance levels under eIDAS being accepted

Tighter UBO (Ultimate Beneficial Owner) Requirements

Consultation with national UBO registers is no longer sufficient.
Firms must actively verify UBOs and can only default to Senior Managing Officials (SMOs) after all possible means of identification are exhausted.
UBO registers (e.g., Swedish Companies House) are getting enhanced mandates to ensure accuracy and transparency.

Cash Payment Limits

Companies are prohibited from accepting cash payments above €10,000.
Exemptions apply only under strict transparency and registration conditions (e.g., for Swedish companies via Bolagsverket).

New Sectors Under Supervision

Crypto asset service providers (CASPs) under MiCA
Professional football clubs and agents, reflecting concerns around sports-related money laundering

These measures reflect a risk-based approach, aiming to place controls where vulnerabilities are most visible.

The International Context: Aligning with Global Standards

The EU isn’t acting alone. The AML Package is part of a larger push aligned with:

The Financial Action Task Force (FATF) standards
Transfer of Funds Regulation (TFR), now updated for crypto
MiCA and the upcoming PSD3 directive, which address fraud and digital assets

This alignment ensures that EU-level reforms can be mirrored globally, strengthening financial integrity across borders and reducing systemic risk.

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Conclusion: Are Companies Ready?

The AML Package has been years in the making and while implementation will stretch into 2029, the time to prepare is now.

Companies need to:

Reassess governance and compliance frameworks
Evaluate onboarding and due diligence procedures
Monitor the finalization of RTS on CDD, which will set the new operational standard

While the AMLR, AMLA and revised directives represent regulatory complexity, they also provide clarity, consistency and opportunity – especially for firms that move early.

How Sinpex Can Help

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