2026: A Pivotal Year Ahead of the European “Single Rulebook”

After several years of negotiation, the European Anti-Money Laundering legislative package (AML Package) is entering its implementation phase.
The European Union is preparing a major overhaul of the AML/CFT framework based on three pillars:

• the creation of AMLA,

• the AMLR Regulation (Single Rulebook),

• and the 6th Anti-Money Laundering Directive (6AMLD) focusing on the criminal framework.

For asset managers, funds, and all regulated entities, 2026 will be the year to prepare for this new regulatory landscape.

AMLA — the New European Anti-Money Laundering Supervisory Authority

What it is

The Anti-Money Laundering Authority (AMLA) will be the new EU agency dedicated to AML/CFT supervision, based in Frankfurt.
Its goal: ensure consistent application of AML/CFT rules across the EU.

Its role

• Direct supervision of high-risk entities (systemic banks, cross-border groups, crypto-asset service providers)

• Coordination of national supervisors (ACPR, CSSF, BaFin, etc.)

• Setting common standards and compliance best practices

Key timeline

• Mid-2025: operational launch

• 2026: staffing and first technical standards

• 2028: start of direct supervision for “high-risk” entities

What this changes for asset managers

• End of national discrepancies: a unified EU framework

• Strengthened controls and documentation requirements

• Preparation for potential EU-level audits for cross-border actors

Sources: Council of the EU, Regulation (EU) 2024/1620

AMLR — the European Single Rulebook

What it is

Regulation (EU) 2024/1624, known as AMLR, creates a uniform and directly applicable set of AML/CFT rules across the EU.
It will fully apply on 10 July 2027.

What changes

• Single EU cash payment limit: €10,000 (member states may apply lower thresholds)

• Harmonised CDD/EDD obligations: strengthened risk-based approach and controls for certain profiles

• Broader AML/CFT scope: inclusion of new professions (crypto players, sports agents, luxury sector…)

• Enhanced transparency: improved traceability of beneficial owners (UBOs)

Regulation (EU) 2024/1624 — entered into force on 9 July 2024, applicable from 10 July 2027.
Sources: EUR-Lex 2024/1624, Council of the EU.

6AMLD — the Directive on Criminal Law and Governance

What it is

Directive (EU) 2024/1640, known as 6AMLD, complements AMLR by defining national frameworks:

• Harmonisation of money laundering offences

• Strengthening of minimum sanctions

• Increased liability of legal persons

• Enhanced cooperation between Financial Intelligence Units (FIUs)

Timeline

• Published: 19 June 2024

• Transposition deadline: 10 July 2027

• Some technical measures (e.g., property registers): until 2029

Source: Directive (EU) 2024/1640

What to Anticipate Between 2025 and 2028

Checklist for Asset Management Companies

• Update KYC/KYB policies according to AMLR requirements

• Review EDD processes (PEPs, crypto, HNWI, sensitive sectors)

• Refresh AML/CFT risk mapping

• Digitise KYC/AML workflows to keep pace with regulatory change

• Train compliance and internal control teams on the new European framework

In Summary

Europe is entering a new era of integrated supervision with AMLA, AMLR, and 6AMLD.
These reforms will unify AML/CFT standards, strengthen controls, and require significant modernisation of internal processes.

For asset managers, 2026 is the year to upgrade policies, tools, and compliance culture to be ready for 2027.

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Official References

• Council of the European Union – AMLA

• Regulation (EU) 2024/1620 – creation of AMLA

• Regulation (EU) 2024/1624 – AMLR, Single Rulebook

• Directive (EU) 2024/1640 – 6AMLD