The European Union’s anti-money laundering and counter-terrorist financing framework has increasingly focused on consistency and effective information exchange between Member States. Against this background, the Anti-Money Laundering Authority, hereinafter referred to as AMLA, has launched a public consultation on a proposed common format for reporting suspicions and providing transaction records to Financial Intelligence Units, hereinafter referred to as FIUs.
This initiative forms part of the wider reform introduced through Regulation (EU) 2024/1624, commonly referred to as the Anti-Money Laundering Regulation or AMLR. Article 69(1) AMLR requires businesses and professionals subject to AML/CFT obligations to report, on their own initiative, suspicions that funds or activities may be linked to criminal activity, terrorist financing, or the proceeds of crime. Article 69(3) AMLR then requires AMLA to specify the format to be used for such reports and for the provision of transaction records. Accordingly, the proposal does not introduce a new reporting duty, but seeks to harmonise how existing obligations are fulfilled across the Union.
This harmonisation is intended to address the current differences between national reporting systems. At present, the information requested, report structure and technical method of submission may vary between Member States. This can create uncertainty for cross-border operators and may make it harder for FIUs to compare, analyse and exchange information efficiently. AMLA’s proposal seeks to address these issues by introducing a common reporting structure, while still allowing for sector-specific and national practicalities.
At the centre of the proposal is a common set of data points. These are the pieces of information that may need to be included when a report of suspicion is submitted or when transaction records are provided. The draft Annexes include data points relating to the reporting entity, the report itself, the urgency of the matter, the reason for suspicion, the persons or legal entities involved, contact details, accounts, transactions, products and services, and other relevant information.
However, the proposed framework is not intended to impose the same reporting burden in every case. Although the Annexes contain an extensive list of data points, obliged entities would only be required to complete the data points that are relevant to their activity and to the type of suspicion being reported. AMLA’s approach is therefore based on one common EU structure, but with reports tailored to the circumstances of the case.
The proposal also distinguishes between different levels of data-point treatment. Some data points are technically mandatory or technically required, meaning that they are necessary for the reporting system or template to function properly. Others are mandatory, mandatory if available, optional, or FIU-required. This distinction recognises that an obliged entity may not always have access to every piece of information at the time of reporting.
To support the practical application of these categories, AMLA has also published an Interpretative Note, which explains how the relevant data points should be understood and completed. The Note is intended to support consistency between FIUs and reporting entities, but remains guidance-based. It does not create, amend or replace binding legal obligations and, in the event of any inconsistency, the applicable EU legal acts will prevail.
The term “format” is also used in a broad sense. It does not simply refer to the file type or technical system through which a report is submitted. Instead, it refers both to the content of the report and to the way in which that content is structured. This includes the data points themselves, together with technical elements such as definitions, values and attributes. AMLA has not proposed one single technical language or file format for all Member States. This reflects the fact that national reporting systems already differ in their design and level of technological development. Instead, the draft standards seek to work with existing systems, while encouraging the use of machine-readable formats where possible.
To facilitate the practical application of the proposed framework, AMLA has also published an Interpretative Note. This document explains how the relevant data points should be understood and completed, thereby supporting a more consistent approach by FIUs and reporting entities. Its role, however, is guidance-based. It does not create, amend or replace binding legal obligations, and in the event of any inconsistency, the applicable EU legal acts will prevail.
This practical focus is also reflected in AMLA’s proposed phased approach. Given the scale of the changes involved, the common format is not intended to be introduced immediately in full. The first phase will allow FIUs to assess the proposed data points against the information currently collected under their national systems. AMLA will then coordinate a process to refine and, where necessary, adapt the format. In a later phase, the format will be incorporated into the systems used by FIUs and reporting entities. This gradual approach is intended to ensure that harmonisation remains workable and that both public authorities and the private sector have sufficient time to prepare.
For businesses and professionals subject to AML/CFT obligations, the proposal may provide greater clarity and predictability. Entities operating across borders may benefit from a more consistent reporting structure, reducing the need to adapt to substantially different national templates. At the same time, implementation may require practical changes, including updates to internal procedures, reporting systems, staff training and compliance policies.
For FIUs, the expected benefit lies in receiving information that is more structured and easier to compare. This may support better analysis, prioritisation and cooperation between authorities, particularly in cases involving more than one Member State. In this sense, the proposed reporting format is not merely an administrative exercise. It forms part of a broader move towards a more integrated and data-driven EU AML/CFT framework.
From a Maltese perspective, the proposal is relevant to the national reporting framework administered through the Financial Intelligence Analysis Unit. Although Malta already has an established AML/CFT reporting system, the introduction of a common EU format may still require adjustments to internal systems and reporting processes, particularly where activities have a cross-border dimension.
Overall, AMLA’s draft Implementing Technical Standards represent an important step towards greater consistency in the reporting of suspicions and transaction records across the European Union. The proposal seeks to bring together harmonisation and practicality by establishing a common EU structure while allowing reports to be tailored to the reporting entity and the nature of the suspicion.
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Author: Alesea Azzopardi Spiteri