EBA, AMLA ¦ EBA and AMLA Complete Handover of AML/CFT Mandates

Strengthening EU Financial Integrity – What the EBA–AMLA Transition Means for Anti‑Money Laundering and Counter‑Terrorist Financing

The formal transfer of the European Banking Authority’s (EBA) anti‑money laundering and countering the financing of terrorism (AML/CFT) powers to the new Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) marks a decisive shift in the EU’s approach to financial crime. The handover – completed at the turn of 2026 after preparatory steps in 2025 – creates a centralised European authority tasked with completing a harmonised Single Rulebook, coordinating supervision across sectors, and raising the consistency and quality of AML/CFT enforcement across member states. For practitioners, supervised entities and regulators, the transition brings regulatory continuity and new supervisory realities to plan for.

Jump to: Luxembourg-specific considerations

A centralised mandate with broad reach

AMLA’s mandate positions it as the EU’s central AML/CFT supervisor and rule‑maker. It inherits the EBA’s technical work, databases and risk insights, and will build on those foundations to produce binding regulatory technical standards and guidance that apply across financial and non‑financial sectors. The new authority is charged with finishing the Single Rulebook – a uniform set of AML/CFT rules intended to reduce fragmentation and ensure consistent application across the Union.

From 2028, AMLA will directly supervise up to 40 of the most complex and high‑risk financial institutions or groups.

For the remainder of the financial sector, AMLA will exercise indirect supervision through common standards and supervisory practices while national authorities continue day‑to‑day oversight.

AMLA’s remit will also extend into non‑financial obliged entities and include coordination and technical support to national Financial Intelligence Units (FIUs), improving cross‑border intelligence sharing.

Regulatory continuity and the role of the EBA

Article 54 of the AMLA Regulation ensures that existing EBA AML/CFT guidelines and standards remain in force until AMLA formally replaces them, providing essential regulatory certainty during the transition. The EBA will not disappear from the AML/CFT landscape. Instead, its role shifts to a prudential safeguard against money laundering and terrorist financing risks. The EBA will embed ML/TF risk considerations into authorisations, fit-and-proper assessments, governance and ongoing prudential supervision. It will promote consistent prudential supervision, collaborate with AMLA on joint instruments such as guidance on de‑risking, and monitor emerging market and regulatory threats that require coordinated responses.

Bastian Schwind-Wagner _Follow

"The transfer of AML/CFT powers from the EBA to AMLA creates a single EU authority tasked with delivering harmonised rules and stronger cross‑border supervision, while preserving regulatory continuity during the transition. This change should improve consistency in enforcement and intelligence sharing, but its success depends on seamless cooperation between AMLA, the EBA and national authorities.

Firms and supervisors must maintain compliance with existing guidelines now in force while preparing for stricter, harmonised standards and possible direct supervision of large, high‑risk groups. Prioritising governance, data quality and cross‑border readiness will be essential to meet AMLA’s expectations and to strengthen the EU’s defences against financial crime."

Operationalising cooperation – MoU and shared tools

To avoid fragmentation and preserve momentum, AMLA and the European Supervisory Authorities (the EBA, EIOPA and ESMA) signed a Memorandum of Understanding in mid‑2025. That agreement establishes channels for information exchange, joint initiatives and cross‑sector learning. The handover included transfer of critical EBA tools and datasets, including the EuReCa database and supervisory risk assessments – assets that give AMLA an immediate operational capability. Practical cooperation arrangements and shared methodologies are designed to prevent gaps between prudential and AML/CFT supervision and to ensure that supervisory interventions are consistent, evidence based and timely.

What changes for regulated entities and supervisors

For banks, payment service providers, crypto‑asset service providers, investment fund managers and other obliged entities, the immediate message is continuity coupled with forward planning. Current EBA guidelines remain applicable until AMLA publishes replacements, and AMLA will provide transition periods when new rules are introduced. Firms should therefore continue to follow existing guidance while monitoring AMLA’s rulemaking timetable and preparing for potentially stricter and more harmonised expectations.

High‑risk, large and cross‑border groups should expect enhanced scrutiny once AMLA begins direct supervision of selected entities in 2028.

National supervisors will remain on the front line for most entities, but will increasingly align practices with AMLA’s standards, meaning national enforcement and supervisory approaches will become more uniform over time.

Implications for FIUs and financial intelligence sharing

AMLA’s coordinating role for FIUs aims to tackle long‑standing obstacles to effective cross‑border financial intelligence exchange. By providing technical resources, common standards for information handling and enhanced coordination mechanisms, AMLA seeks to raise the quality and timeliness of intelligence shared across member states.

For investigators and compliance teams, this should gradually translate into clearer expectations about reporting quality, more consistent feedback loops with supervisors and potentially faster cross‑border responses to complex laundering and terrorist financing schemes.

Key risks and areas to watch

The transition reduces regulatory fragmentation risks but introduces new challenges. Effective cooperation between AMLA and prudential supervisors is critical to avoid regulatory blind spots where ML/TF risks intersect with financial stability. The successful operationalisation of data and analytical tools transferred from the EBA will determine AMLA’s early effectiveness.

Supervisory capacity building – including joint training on emerging technologies such as crypto‑assets – will be essential to implement harmonised standards across jurisdictions with differing resources and expertise.

Finally, the political and legal dynamics within member states around direct supervision of large institutions may generate friction; transparent criteria for AMLA’s supervisory selection and robust appeal and accountability mechanisms will be central to long‑term acceptance.

Practical next steps for compliance and supervisory teams

• Continue applying all existing EBA AML/CFT guidelines while mapping the organisation’s AML/CFT program against likely AMLA expectations.
• Track AMLA’s publications and rulemaking timetable closely and maintain engagement with national supervisors to understand how national practices will align with AMLA standards.
• High‑risk and cross‑border groups should prepare for potential direct supervision, strengthening governance, transaction monitoring, customer due diligence and suspicious activity reporting processes.
• FIUs and compliance functions should prioritise data quality and the operational readiness to respond to cross‑border requests, while investing in staff training on AMLA‑driven methodologies and any new technical standards that emerge.

Luxembourg-specific considerations

Positioned within Luxembourg’s robust regulatory environment, the AMLA–EBA transition interfaces directly with the CSSF’s/AED’s supervisory remit and the country’s diversified financial ecosystem. Luxembourg’s banks, investment funds, investment fund managers, professionals of the financial sector (PSFs) and growing FinTech segment operate under CSSF/AED supervision while complying with EU AML/CFT rules; the emergence of AMLA as the EU central authority reinforces expectations for consistent application of those rules locally and for closer alignment between CSSF/AED practice and forthcoming AMLA standards.

The CSSF/AED is likely to focus supervisory attention on governance frameworks, senior management accountability, adequacy of risk assessments and the quality of suspicious activity reporting, consistent with its historical priorities. Supervisory reviews will emphasise documented policies and procedures, fit‑and‑proper assessments for key roles, evidence of effective transaction monitoring, and clear audit trails for customer due diligence and enhanced due diligence measures.

For Luxembourg entities, practical implications include strengthening governance and formal documentation, enhancing controls around investment fund structures and cross‑border flows, and ensuring PSFs and FinTechs demonstrate scalable transaction monitoring and reporting capabilities. Firms should prepare comprehensive documentation of risk appetite, decision‑making and model validation, and be ready to present evidence of timely remediation of control gaps identified by internal or CSSF/AED reviews.

Conclusion – a more unified European AML/CFT architecture

The transfer of AML/CFT powers from the EBA to AMLA is a structural reform designed to deliver a more consistent, coordinated and effective European response to financial crime. It preserves regulatory continuity by keeping EBA standards in force during transition, while creating a central authority with the mandate and tools to complete a Single Rulebook and to directly supervise the most complex, high‑risk entities. The EBA remains an essential partner, focused on embedding ML/TF risks in prudential oversight and collaborating with AMLA to avoid gaps. For industry and supervisors, the immediate task is to sustain compliance with existing rules while readying for a new, more harmonised supervisory landscape. The long‑term promise is clearer rules, better intelligence sharing and stronger defences against money laundering and terrorist financing across the EU.

Dive deeper

• AMLA ¦ EBA and AMLA complete handover of AML/CFT mandates ¦ Link