What does AMLR mean in practice?

Which areas are already most affected?

We follow developments around AMLR and the future RTSs closely and carry out ongoing gap analyses to ensure that CM1 is developed in line with future regulatory requirements. Although not all RTSs have yet been published, we already see several clear regulatory directions that are likely to affect future AML work.

Harmonization is becoming the new standard

• A more common AML regulatory framework is emerging within the EU.
• There is an increased focus on joint AML processes within groups.
• Common risk assessments and control frameworks are becoming more important.
• Central control and coherent risk management are becoming increasingly important.

AML work is becoming more dynamic

• Ongoing monitoring is becoming more important.
• Changed customer behavior has a greater impact on AML work.
• Deviant behavior and risk indicators are becoming more important.
• Risk classifications are expected to become more dynamic.

Sanction risk is more clearly integrated into AML work

• Increased focus on sanction evasion and complex networks
• Sanction risk becomes a clearer part of the overall risk assessment
• Increased focus on ownership structures, control, and beneficial owners
• Links between individuals, companies, and networks are becoming more important

What does this mean in practice?

• Increased requirements for ongoing monitoring
• Greater focus on documentation and traceability
• Risk assessments need to become more data-driven and dynamic
• Data, analysis, and system support are becoming increasingly important for effective AML work

We are actively working to ensure that CM1 is continuously developed in line with upcoming requirements, and we see that many of the initiatives already being discussed within CM1 align closely with the regulatory developments under AMLR.