Insights
EU AML rulebook (AMLR): what changes for enhanced due diligence
The EU's new anti-money laundering rulebook changes where the rules sit and how consistently they apply. For enhanced due diligence teams, the practical effect is a stronger need for documented, repeatable evidence.
What is the AMLR?
The EU adopted an anti-money laundering package in 2024. Its centerpiece is Regulation (EU) 2024/1624, known as the AMLR. Unlike a directive, a regulation applies directly in every member state, so firms in different countries work from the same text instead of separate national versions.
The package also created a new EU authority, AMLA, based in Frankfurt. It will directly supervise a small number of high-risk cross-border entities and coordinate national supervisors.
When does it apply?
The AMLR applies from 10 July 2027. Firms have until then to align their processes.
What it means for enhanced due diligence
The AMLR sets out, in one directly applicable text, the customer due diligence measures that obliged entities must apply. That includes when enhanced measures are required, for example for business relationships involving high-risk third countries identified by the European Commission and for politically exposed persons. It also harmonises how beneficial owners are identified.
For EDD teams this points to two things: more consistent expectations across borders, and a greater need to show how each conclusion was reached.
What teams can do now
- Map where EDD evidence comes from today and how long each step takes.
- Standardize the scope report so that every case records the same items.
- Keep a source trail and a review record for each case.
- Follow guidance from your supervisor and from AMLA as it is published.
- Agree with legal and compliance which parts of your process need to change.
Where Bletchley fits
Bletchley prepares source-linked scope report drafts, so the evidence trail is built in as the report is prepared. Analysts review and decide. Bletchley does not provide legal advice and does not decide what the rules require of you. See the enhanced due diligence overview.