The 2024 EU AML/CFT package introduces a harmonized European framework to strengthen supervision, cooperation and the prevention of financial crime. Its Single Rule Book comprises the directly applicable Anti-Money Laundering Regulation and Directive, which must be implemented nationally. From July 2027, all Member States must comply with the new framework.

The new European authority, The Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), will directly supervise selected high-risk, cross-border financial institutions from 2028 and indirectly oversee others by establishing common supervisory standards and methodologies. De Nederlandsche Bank (DNB) will cooperate closely with AMLA, contribute experts to Joint Supervisory Teams and adapt its processes, technical capabilities and guidance to the European framework.

Many aspects of the AML/CFT package and AMLA have yet to be fully clarified. Over time, the precise scope of the legislation and how AMLA will fulfil its role will become clearer. This article is based on the information available to date and is not intended to establish supervisory expectations.

Financial institutions and trust or company service providers which fall under the supervision of DNB will face more detailed and stringent obligations. Some of these key changes will be covered in this article and relate to internal controls, the risk assessment, the compliance function, customer due diligence and beneficial ownership requirements. Trust service providers will always be required to apply enhanced customer due diligence. The UBO threshold will change to 25% or more, potentially requiring institutions to reassess ownership structures.

The AMLR also replaces the Dutch unusual-transaction reporting system with a suspicion-based regime, incorporates targeted financial sanctions into AML/CFT risk management and generally requires every obliged entity to appoint a compliance officer. Institutions should therefore begin impact assessments, identify relevant data requirements, adapt policies and systems, and actively participate in AMLA consultations.

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