AMLR Compass

Navigating tomorrow. Understanding the new regulation. Structuring implementation.

Overview

Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLR) is a central component of the EU anti-money laundering package adopted in 2024. Through the AMLR, the EU introduces a single rulebook: uniform, directly applicable regulation are intended to close gaps and reduce divergences between national regulation and to further harmonise the prevention of money laundering and terrorist financing. The AMLR also addresses the risks of non-implementation and evasion of targeted financial sanctions.

The AMLR applies in the EU Member States from 10 July 2027. Its application in the EEA States, including Liechtenstein, will depend on the timing and terms of its incorporation into the EEA Agreement.

The AMLR may also be relevant to Swiss financial intermediaries, for example through a branch or subsidiary in the EU/EEA, or as part of a group with obliged entities in the EU/EEA.

Unlike Directive (EU) 2024/1640 (AMLD6), which also forms part of the EU anti-money laundering package, the AMLR does not need to be transposed into national law of the EU Member States, as it is directly applicable. Therefore, the due diligence requirements applicable to obliged entities will in future derive predominantly from the AMLR itself.

With the AMLR Compass, reeeg helps you navigate this paradigm shift. The AMLR Compass focuses exclusively on the requirements of the AMLR.

Navigating tomorrow: The AMLR Compass maps the new articles of the AMLR to familiar subject areas, making it easier to locate the relevant provisions.

Understanding the new regulation: The AMLR Compass explains the new provisions of the AMLR and makes the resulting obligations easier to understand.

Structuring implementation: To support a structured implementation, reeeg has supplemented the AMLR Compass with potential areas for action. These serve as a first set of guidance for practical implementation. reeeg will be pleased to provide you with the AMLR Compass including the areas for action, free of charge upon request.

Disclaimer

The content is provided for general information and guidance. It does not constitute legal advice or a binding legal interpretation. It is not a substitute for consulting the binding legal sources or assessing the circumstances of an individual case. The AMLR Compass makes no claim to be complete or up to date.

 

The AMLR

Definitions

Scope

Internal organisation

Business-wide risk assessment

Compliance functions and AML Officer

Training, awareness and integrity

Group-wide requirements

Outsourcing

Application of customer due diligence

Scope of customer due diligence

Customer risk assessment (CRA)

Customer identification

Beneficial ownership

Business relationship profile

Ongoing monitoring, KYC reviews and updating customer information

Targeted financial sanctions

Simplified due diligence

Enhanced due diligence

Politically exposed persons

Reliance on third parties

Analysis of suspicions, STRs/SARs and requests for information

Freezing of assets and prohibition of disclosure (“tipping off”)

Data protection, documentation and record retention