Everything you need to know about the so-called “AML package”, the regulatory updates issued by the European Union in the normative area of anti-money laundering
The documents included into the EU “AML package” and the covered normative areas
In recent months, the expression “AML package” has become a common refrain in conversations between financial compliance professionals within the European Union.
With “AML package”, in fact, is designated the reform package concerning anti-money laundering and counter-terrorist financing, made up by the Directive (EU) 2024/1640 (also known as “6th Anti Money Laundering Directive”), the Regulation (EU) 2024/1624 (the so-called “Anti-Money Laundering Regulation”) and the Regulation (EU) 2024/1620 (the “AMLA Regulation”), all issued on 31 May 2024.
More specifically:
- the 6th Anti-Money Laundering Directive addresses the mechanisms that EU member states must establish to prevent the use of the financial system for the purpose of money laundering or terrorist financing, amending Directive (EU) 2019/1937 and repealing Directive (EU) 2015/849;
- the Anti-Money Laundering Regulation (also known as “single rulebook”) is focused on preventing the use of the financial system for money laundering or terrorist financing;
- the AMLA Regulation establishes the Anti-Money Laundering Authority (hence the acronym “AMLA”) and amends Regulations (EU) No. 1093/2010, (EU) No. 1094/2010 and (EU) No. 1095/2010.
In short, the AML package is a comprehensive and very relevant intervention by European regulators in the normative areas of anti-money laundering and combating terrorist financing.
An intervention that the entire EU financial ecosystem will have to deal with, and which is therefore leading – and will lead – to intensive regulatory analysis performed by compliance departments of all the organizations operating in the financial sector.
AML package: what’s new? The general content of the EU regulatory package
Before discovering how Aptus.AI’s RegTech platform can optimize and make more effective the regulatory transposition of the AML package, it is worth summarizing what are the main obligations that this new regulatory package introduced within the European Union.
In particular, the principal innovations can be found within two of the three documents that make up the package, namely the Anti-Money Laundering Regulation and the 6th Anti-Money Laundering Directive.
An important first element is the introduction of the right to immediate, unfiltered, direct and free access to beneficial owner information in national registries for all those who can demonstrate a legitimate interest (journalists, civil society organisations, competent authorities and supervisory bodies).
In addition, the two aforementioned documents give more powers to the Financial Intelligence Units (FIUs) and establish additional due diligence measures, enhanced controls on the identity of customers and additional reporting requirements for obligors.
Besides, the 6th Annex to the Anti-Money Laundering Regulation also introduces the definition of high-value goods (jewellery, watches and articles in gold or silver of a value exceeding 10.000 euros, motor vehicles of a value exceeding 250.000 euros, aircraft and boats of a value exceeding 7,5 million euros) and the extension also to professional football clubs of customer identity checks, transaction monitoring and suspicious transaction reports to FIUs.
Finally, the Anti-Money Laundering Regulation and the 6th Anti-Money Laundering Directive also include new supervisory provisions for individuals with a total assets of at least 50 million euros, excluding their principal residence, and the inclusion of a limit of 10.000 euros for cash payments within the EU, except between private individuals, in a non-professional context.
In addition to these key points, the AML package includes a series of new obligations for financial operators, causing the compliance teams of these organizations to identify the regulatory gap between the obligations introduced by the AML package and the already carried out compliance adjustments under the regulations issued previously, to assess the real impact of the introduction of the AML package on the specific organisation.
Anti-Money Laundering Regulation and 6th Directive: entry into force and deadlines
Luckily for financial operators, the transposition of the obligations introduced by the AML package will not have to be immediate.
The 6th Anti-Money Laundering Directive, which has already entered into force on the twentieth day following its publication in the Official Journal of the EU, must be transposed by member states into their national legislation by 10 July 2027.
However, there are exceptions in Articles 11, 12,13 and 15 (relating to the beneficial owner register), which must be implemented by 10 July 2026, and in Article 18 (concerning the single point of access to real estate information), which must be transposed by 10 July 2029.
The Anti-Money Laundering Regulation is also in force from the twentieth day after publication, but it will apply as of 10 July 2027, except for football agents and professional football clubs, to which will apply from 10 July 2029.
Finally, the AMLA Regulation is in force from the seventh day following its publication in the Official Journal of the EU, but will apply as of 1 July 2025.
Assessing the impacts of the AML package can be simple… thanks to Aptus
The regulatory analysis and impact assessment work required of financial institutions’ compliance teams to transpose the AML package will therefore be very challenging.
So demanding that it risks becoming prohibitive in the absence of adequate technological solutions to automate all those steps of the compliance processes where human skills cannot add value.
This is the main goal of Aptus. Using an innovative proprietary machine-readable format of regulatory texts, Aptus.AI’s RegTech platform provides financial compliance professionals with an enhanced version of legal texts, including an advanced research – both internal and external to documents -, in addition to the identification and highlighting of the law parts according to their type (definitions, sanctions, etc.).
Besides, the AI models underlying Aptus automatically extract the requirements and the regulatory obligations included in the AML package, also taking into account the internal processes and policies of the specific organization.
This AI-powered analysis is therefore capable of providing instant and accurate first-impact analyses on any regulatory perimeter, including the AML one.
In a complex context such as the European Union, the Aptus.AI’s solution not only allows organizations to reduce time and costs to transpose regulatory updates, but also to anticipate regulatory trends and transform compliance into a strategic function able to generate business opportunities.
Aptus’ features make the EU regulatory transposition quick and effective
In light of the content of the AML package and considering the complexity of this regulatory update, it is now time to understand how Aptus’ features can help the compliance departments of financial institutions optimize and speed up their processes.
First, Aptus.Outlook allows users to analyse regulatory documents even before their official publication, and therefore to prepare in advance for future updates of the AML package and for all the new documents that the EU will issue on anti-money laundering and counter-terrorism, so as to plan the needed compliance activities to adapt to the European regulatory framework.
Besides, Aptus.Search offers an advanced search engine both internal and external to the regulatory texts included in the AML package, in order to identify immediately the obligations introduced, the possible sanctions and all the relevant information for regulatory compliance.
Finally, to make the consultation of the documents included in the AML package even more intuitive, fast and effective, there is Aptus.Chat, the Generative AI service integrated in Aptus that allows users to directly interrogate regulations in natural language.
Aptus.Chat exploits the legal requirements objectively translated into a digital format and follows the official hierarchy of the norms, being the first reliable and hallucination-free Generative AI solution for the legal sector, being capable of providing legal summaries and assisting in identifying the parts of the regulations which are relevant for the research.
