New EU anti-money laundering package poses challenges for financial intermediaries

With the so-called "Single Rulebook", the EU is establishing, for the first time, a uniform legal framework to combat money laundering and terrorist financing. The reason for this is clear: the previous requirements were based on directives that were implemented differently by individual Member States. This led to national variations, legal uncertainty and, in some cases, differing competitive conditions.

With the new, directly applicable regulations, largely uniform standards will apply throughout the EU and the EEA from 10 July 2027. The aim is to reduce scope for interpretation, create a level playing field and make the fight against money laundering more effective across borders.

For banks, trustees and wealth managers, however, this means a considerable need to adapt. International financial groups, in particular, will in future have to align their risk assessments, internal controls and training group-wide in accordance with uniform guidelines. Processes that could previously be regulated locally will be more closely harmonised and managed centrally.

Financial intermediaries will have to collect and document more information in future. In addition to additional personal data, greater focus will be placed on the actual ownership and control structures of companies. The effort required for analysis and documentation will increase significantly, particularly in the case of complex shareholding structures.

The real challenge, however, lies in implementing the new regulatory requirements efficiently without compromising the client's experience. Those institutions that successfully combine regulatory obligations, digital processes and client-friendly communication will be the ones to succeed.

The European "Single Rulebook" is far more than a legal adjustment. It represents a further step towards a transparent, resilient and harmonised financial centre. Even though the deadline in July 2027 is still some way off, preparations for the new requirements have long since begun for many market participants subject to these obligations.

Of particular importance in the implementation of the EU Anti-Money Laundering Package is the identification of risks that have impacts on the business activities of obliged entities. In this regard, the central supervisory authority, the AMLA (Anti-Money Laundering Authority), will issue guidelines setting out the minimum requirements for a company-wide risk assessment. According to the text of the AML Regulation, this stipulates, at the very least, that the principle of proportionality must be upheld when applying the requirements. How this can be ensured in practice will become clear over the coming months.