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How to Prepare for the 2027 EU AML Reform: What Will Change and Why You Must Act in 2026
Introduction
The AML landscape in the European Union is on the brink of major change. With the adoption of the EU AML Package and the establishment of the Anti-Money Laundering Authority (AMLA), financial institutions across the EU face an era of stricter supervision, increased reporting obligations, and higher compliance standards.
While full enforcement is expected by 2027, the time to act is now. Institutions that begin remediation and operational preparation in 2026 will be best positioned to remain compliant and competitive.
1. What Is the EU AML Package?
The AML Package adopted by EU legislators introduces several legislative changes:
- A new single AML Rulebook that harmonizes requirements across the EU.
- The creation of AMLA, which will directly supervise high-risk financial institutions and coordinate national authorities.
- New, stricter standards for customer due diligence, beneficial ownership transparency, and transaction monitoring.
- Expansion of AML/CFT obligations to new sectors.
These changes affect all obliged entities, including:
- Banks (especially cross-border groups),
- Payment institutions,
- Accounting and tax advisory firms,
- Crypto-asset service providers (VASPs / CASPs).
2. What Will Change for Financial Institutions?
A. Supervision by AMLA
Banks and other high-risk institutions operating cross-border will be subject to direct EU-level supervision by AMLA. This includes periodic audits, thematic inspections, and requests for information.
B. Enhanced Customer Due Diligence (CDD)
Institutions will need to:
- Reassess risk profiles,
- Update and document KYC files,
- Integrate PEP and sanctions screening with near real-time monitoring,
- Implement risk-based negative media screening.
C. Transaction Monitoring Overhaul
Regulators expect continuous, rules-based and behavior-based monitoring. Institutions will need to:
- Calibrate monitoring scenarios to risk,
- Document decisions around false positives,
- Conduct back-testing and effectiveness reviews.
D. Beneficial Ownership Register Compliance
Institutions must ensure ongoing and consistent checks of beneficial ownership (UBO) information with public and commercial registers.
E. Outsourcing, Governance, and Auditability
Institutions must:
- Maintain full control and documentation of outsourced AML activities,
- Provide evidence of oversight and quality assurance,
- Be able to demonstrate compliance in external audits.
3. What Should You Do in 2026?
2026 will be a crucial preparation year. Institutions should:
- Conduct an AML/CFT gap analysis against the upcoming Rulebook.
- Begin KYC file remediation, especially for legacy customers.
- Upgrade AML systems for transaction monitoring, sanctions and media screening.
- Prepare for potential AMLA audits by documenting controls.
- Ensure outsourced AML services are contractually and operationally compliant with new expectations.
4. How APOG Can Help
At APOG, we support institutions in meeting complex AML/CFT obligations through tailored outsourcing and consulting services:
- KYC Remediation: Large-scale review and updating of customer files.
- Sanctions & PEP Screening: Design and operation of automated screening programs.
- Adverse Media: Integrating external media databases and periodic monitoring.
- Transaction Monitoring: Outsourcing of alerts review and scenario tuning.
- Internal Audit & AML Review: Third-party assessments aligned with EU AML standards.
Whether you are a bank preparing for AMLA supervision, a payment institution scaling operations, or a crypto firm transitioning under MiCA – we help you stay ahead of the curve.
Conclusion
The EU AML reform is not just another compliance update – it’s a transformation. From 2027, the expectations placed on obliged institutions will increase significantly. The institutions that act in 2026 to understand, plan and implement required changes will benefit most from a smoother transition and lower risk exposure.
Let APOG help you prepare – with deep regulatory insight and hands-on support.
