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Implications of the timeline and readiness requirements
The timeline for the EU AML package sets out clear milestones that financial institutions must follow to strive for legal compliance and readiness:
- 2025: The European Banking Authority (EBA) finalized the draft report for the first set of Regulatory Technical Standards (RTS).
- 2026: The Anti-Money Laundering Authority (AMLA) assumed responsibility for the preparation of AML/CFT regulation. AMLA has published the final reports for two Regulatory Technical Standards (RTS) and has launched consultations on additional RTS and Implementing Technical Standards (ITS). Over the course of the year, several Level 2 and Level 3 regulatory measures are expected to be issued. All affected institutions – including banks, payment service providers, investment firms, and other entities subject to AML and KYC requirements – should conduct a comprehensive gap analysis. This involves reviewing existing AML policies, procedures, and compliance frameworks to identify necessary changes in light of the forthcoming standards.
- 2027: The AMLR (Regulation EU 2024/1624) and AMLD6 (Directive EU 2024/1640) will come into effect, and centralized registers will become operational. All financial institutions must be fully compliant with the new harmonized rules and try to ensure their systems are integrated with EU-wide beneficial ownership and account registers. By this stage, institutions are expected to have updated their internal policies, systems and operational processes. The reason for doing so is to strive for full alignment with the finalized regulatory requirements.
- 2028: The new EU AMLA will assume direct supervisory powers, especially over high-risk or cross-border institutions. By this stage, institutions must be prepared for direct oversight, stricter enforcement and enhanced due diligence (EDD).