AML-CTF Package – What is it and the timeline

The EU Anti-Money Laundering and Counter-Terrorist Financing (AML-CTF) package is composed of four legislative texts, all of which aim at harmonising and strengthening AML-CTF rules across the European Union.

The package includes:

The Anti-Money Laundering Directive (AMLD), which addresses the organisation of the AML-CTF framework at national level, including, for example, cooperation between competent authorities and access to registers of beneficial owners.

The Anti-Money Laundering Regulation (AMLR), which sets out the core obligations and requirements for the private sector, with directly applicable rules covering customer due diligence, beneficial ownership, internal controls, reporting obligations and related matters.

The AMLA Regulation (AMLAR), establishing the new EU anti-money laundering authority entrusted with the direct supervision of certain high-risk entities – the Authority for Anti-Money Laundering and Countering the Financing of Terrorism.

The Transfer of Funds Regulation (TFR), which entered into force on 30 December 2024.

Implementation timeline

The different components of the AML-CTF package follow distinct implementation schedules:

Next steps for professionals

In practice, the AMLR represents the key text for professionals subject to AML-CTF obligations.

Organisations within scope should:

• carry out a gap analysis in order to identify any potential discrepancies between current practices and upcoming requirements;
• prepare for implementation of the AMLR framework;
• take into account that AMLA has already begun its operations.

Extended scope of obliged professionals under the AMLR

In addition to strengthening existing requirements, the AMLR also extends the scope of professionals subject to AML-CTF rules.

This extension is driven by the need to address emerging risks of money laundering and terrorist financing within the EU market.

Newly in-scope entities

New categories of obliged entities include:

• Crypto asset service providers (CASPs), as defined under MiCA;
• Crowdfunding service providers and intermediaries;
• Professional football clubs and agents, in relation to certain transactions;
• Providers of gambling services, with an option given to Member States not to apply all or some AMLR requirements under specific conditions.

High-value goods traders

The scope also covers:

• Persons trading in high-value goods as a regular or principal professional activity.

A list of high-value goods is set out under the AMLR and includes, for instance:

• jewellery or clocks with a value exceeding EUR 10,000;
• motor vehicles with a price exceeding EUR 250,000.

Practical impact: what you must do

Given the extension of scope, affected entities should take immediate action.

The key steps are as follows:

1. Determine whether you qualify (or will qualify) as an obliged professional under the AMLR;
2. If so, prepare to implement the applicable AML-CTF requirements without delay.

Conclusion

The AML-CTF package marks a significant step towards greater harmonisation and strengthened supervision at EU level, while considerably expanding the perimeter of regulated entities.

Professionals should focus on the AMLR as the central operational text and take proactive measures to assess their status, identify gaps, and ensure timely compliance with the forthcoming framework.

Any questions?

For further information or to discuss how these developments impact your organisation, please contact our key representatives.