AMLA ¦ Work Programme 2025 "From Vision to Action"
AMLA Work Programme 2025: From Vision to Action in the Fight Against Financial Crime
The year 2025 marks a milestone in the European Union’s coordinated efforts to combat money laundering (ML) and terrorist financing (TF) with the operational launch of the Anti-Money Laundering Authority (AMLA). Established by Regulation (EU) 2024/1620, AMLA represents a new central EU agency tasked with harmonizing and strengthening AML/CFT supervision and financial intelligence cooperation across the Union. The AMLA Work Programme 2025 articulates the agency’s foundational activities, strategic priorities, and operational roadmap for its inaugural year.
Foundational Phase: Establishing Structures and Capabilities (First Half of 2025)
AMLA’s initial six months focused heavily on building the infrastructure, governance, staffing, and operational frameworks necessary to fulfill its ambitious mandate.
Physical and Administrative Establishment in Frankfurt
AMLA secured its temporary headquarters in Frankfurt’s Messe Tower by February 2025 and formalized a lease for permanent premises by April. Fit-out works and facility management services were initiated to create a secure, functional work environment aligned with AMLA’s operational needs. This physical presence lays the groundwork for AMLA’s long-term institutional stability.
Governance Framework
The agency swiftly put in place its core governance bodies: the Chair was appointed mid-February, followed by the constitution of the General Board in supervisory and Financial Intelligence Unit (FIU) compositions. The Executive Board was established in June 2025. These entities adopted rules of procedure, including conflict-of-interest policies, ensuring transparency and accountability. AMLA also began fulfilling its accountability obligations towards the European Parliament and Council by documenting key meetings and decisions.
Recruitment and Human Resources
Starting from a skeleton workforce, AMLA prioritized recruitment across critical corporate functions—human resources, IT, finance, procurement—and policy areas. The goal is to reach approximately 120 staff by year-end, including seconded national experts and FIU delegates. AMLA developed onboarding programs, HR management tools, and set foundations for performance management and learning frameworks to integrate and retain talent effectively.
Digital Infrastructure Development
IT was identified as a pivotal enabler of AMLA’s mission. Early efforts focused on establishing a modern digital workplace with secure collaboration tools, administrative systems, and networking infrastructure. Preparations commenced for transitioning key systems such as EBA’s EuReCA AML/CFT database and FIU.net into AMLA’s responsibility. Additionally, the agency began designing its Central AML/CFT Database as mandated by Article 11 of the founding regulation. Cybersecurity frameworks were developed in coordination with EU cybersecurity authorities to protect sensitive data assets.
Institutional Cooperation
AMLA formalized cooperation frameworks through Memoranda of Understanding with European Supervisory Authorities (ESAs) and the European Central Bank (ECB). Furthermore, it welcomed observer participation from EEA/EFTA states (Iceland, Liechtenstein, Norway) on its General Board to foster wider alignment.
Operational Priorities: Preparing for Effective Supervision and FIU Coordination (Second Half of 2025)
With foundational elements in place, AMLA’s focus shifts toward operationalizing its core tasks under the AML/CFT regulatory framework.
Supervisory Mandate Execution
AMLA assumes indirect supervision of non-selected financial institutions and oversight of the non-financial sector starting July 2025. A particular emphasis is placed on high-risk areas such as crypto-asset service providers (CASPs), which present challenges due to technological innovation, cross-border operations, and anonymity features. AMLA will work to harmonize supervisory standards under the Markets in Crypto-Assets Regulation (MICA-R), aiming to reduce jurisdiction shopping risks and supervisory fragmentation.
To facilitate convergence among national competent authorities (NCAs), AMLA will participate in supervisory colleges and organize thematic seminars fostering knowledge exchange. It also plans to conduct risk questionnaires and thematic reviews targeting non-financial supervisors — an area where regulatory harmonization has traditionally lagged — to build comprehensive risk profiles.
Policy Development: Level 2 and Level 3 Measures
AMLA is tasked with drafting 23 secondary legislative measures by July 2026 that complete the EU’s Single Rulebook on AML/CFT. These encompass supervisory procedures, risk understanding by obliged entities (OEs), and FIU operational processes.
Key priorities include:
- Regulatory technical standards (RTS) on the AMLA Database to systematize information collection.
- Implementing technical standards (ITS) governing cooperation mechanisms among supervisors.
- Guidelines on home/host supervisory cooperation.
- Risk-based supervisory methodologies including risk assessment models for financial and non-financial OEs.
- Guidelines on ongoing monitoring and business-wide risk assessments for obliged entities.
AMLA continues close collaboration with EBA and DG FISMA during transition phases to ensure continuity and coherence in rulemaking.
Financial Intelligence Units Pillar Development
AMLA is establishing a robust Support & Coordination Framework for the EU’s FIUs to enhance cross-border cooperation. This includes designating FIU Delegates who will operate within AMLA, enabling faster information exchange and joint operational capability. Preparations are underway for joint analyses exercises targeting cross-border ML/TF typologies and emerging risks, supported by comprehensive mapping of FIU capacities across Member States.
Peer review processes will assess FIU effectiveness and foster convergence. AMLA is also developing working arrangements with law enforcement partners such as Europol, Eurojust, EPPO, and OLAF to facilitate strategic intelligence sharing while respecting operational safeguards.
Strategic Planning: Articulating a Medium-Term Vision
Starting Q3 2025, AMLA will embark on a strategic framework development process culminating in two Single Programming Documents (SPDs) covering 2026–2028 and 2027–2029. This effort involves wide stakeholder consultations within the EU institutions, Member States, NCAs, FIUs, and private sector participants.
The strategic framework will clarify AMLA’s vision, mission, medium-term objectives, performance indicators, resource planning, and set priorities for evolving supervisory and FIU functions. It reflects AMLA’s commitment to a risk-based approach that balances regulatory rigor with proportionality and cost-efficiency.
Risk Management: Navigating Challenges
AMLA acknowledges risks inherent in its start-up phase:
- Capacity constraints due to recruitment delays could hamper timely mandate delivery.
- Dependencies on external institutions and timelines may affect operational rollout.
- Legal uncertainties around new regulatory interpretations pose implementation challenges.
- IT infrastructure development carries cybersecurity risks.
- Early reputational risks exist given high expectations.
To mitigate these risks, AMLA employs prioritization of critical hires, legal reviews, accelerated IT security planning, proactive external communication, and close coordination with EU partners.
Financial Outlook
AMLA operates with a €17.2 million budget for 2025 — comprising €14.2 million from the EU budget and €3 million host country contributions from Germany. By January 2026, AMLA aims to achieve full financial autonomy including integration into the European Commission’s SUMMA financial management system. Internal financial rules are being developed alongside procurement plans aligned with operational needs.
Conclusion: Setting the Cornerstone for Europe’s Fight Against Financial Crime
The AMLA Work Programme 2025 outlines a comprehensive plan transitioning from organizational build-up to active policy shaping, supervision readiness, and intelligence coordination. By establishing governance structures, recruiting skilled personnel, deploying secure IT systems, engaging stakeholders, developing policy frameworks, and managing risks prudently, AMLA is poised to become a cornerstone institution in protecting the EU’s financial integrity.
Its dual mandate — combining direct/indirect supervision with FIU support — enables an integrated approach that enhances detection of illicit financial flows while promoting regulatory convergence across Member States. As AMLA matures over the coming years, it aims to elevate the EU’s capacity to prevent money laundering and terrorist financing through effective enforcement, innovative technology use, collaborative intelligence sharing, and transparent accountability.
In short, 2025 is both a foundational year for AMLA and a critical stepping stone toward building a resilient European anti-financial crime architecture that safeguards citizens’ trust and ensures global leadership in financial security.