The establishment of the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) represents a structural transformation of the European Union’s AML/CFT framework. Through its Single Programming Document (SPD) for 2026–2028, AMLA sets out a detailed and time-bound roadmap toward full operational capacity. This roadmap encompasses the development of a harmonised EU AML/CFT Single Rulebook, the introduction of direct supervision over selected high-risk financial institutions, enhanced coordination among Financial Intelligence Units (FIUs), and the creation of EU-wide risk analysis and supervisory convergence frameworks.
At the core of AMLA’s mandate lies the EU AML/CFT Single Rulebook, which aims to harmonise AML/CFT requirements across all Member States and reduce fragmentation arising from divergent national frameworks. AMLA has identified the further development of the Single Rulebook as its top strategic priority for the 2026–2028 period. This will be achieved through the drafting of Regulatory Technical Standards (RTS), Implementing Technical Standards (ITS), and Guidelines (GL), developed in close cooperation with national authorities and in consultation with the private sector.
Beyond substantive harmonisation, the Single Rulebook is intended to serve as a foundation for supervisory convergence. Under Article 8 of the AML Regulation (AMLAR), AMLA is mandated to develop and maintain a common EU supervisory methodology, ensuring that AML/CFT supervision across the Union is consistent, risk-based, and proportionate to the nature, scale, and residual risk of obliged entities. Work on this methodology will commence in 2026, marking a decisive shift away from fragmented national supervisory approaches.
AMLA will also establish its centralised EU risk analysis framework, which will form the analytical backbone of both its supervisory and FIU-related activities. This will involve mapping relevant data sources, establishing harmonised reporting channels, and developing the procedural and IT infrastructure necessary for systematic data collection and analysis. Its purpose is to support the consistent application of a risk-based approach across AML/CFT supervision and financial intelligence, particularly in the identification and assessment of money laundering and terrorist financing risks.
Significantly, AMLA is expected to reach full operational capacity by 2028. At this stage, it will directly supervise up to forty of the EU’s most impactful financial institutions, selected on a risk-based basis. To enable this, AMLA will complete its risk analysis and selection methodology in 2026, establishing the criteria for selecting obliged entities for direct supervision, with the first selection process to follow in 2027. Direct supervision will include ongoing monitoring, on-site inspections, thematic reviews, and enforcement actions where necessary.
AMLA will also exercise indirect supervision over the broader financial sector through a risk-based and proportionate approach aimed at promoting supervisory convergence. This will involve assessing ML/TF risks, monitoring compliance by obliged entities, and evaluating national supervisory practices and sanctions. Until mid-2027, AMLA’s activities will focus on the current AML/CFT framework, after which attention will shift to monitoring the implementation of the new legislative package.
Moreover, AMLA will develop harmonised indirect supervisory approaches in cooperation with national competent authorities, including common supervisory models, methodologies, and manuals. These will be supported by thematic reviews, supervisory convergence assessments, and structured dialogue.
AMLA’s oversight will also extend to certain selected non-financial sectors. From 2026, it will conduct a comprehensive mapping of supervisory practices across non-financial obliged entities, building on existing information and updating it where necessary. In 2027, this framework will be operationalised through peer reviews, supervisory colleges, and targeted training initiatives. By 2028, AMLA will assess the effectiveness of these measures and review the application of AML/CFT risk assessment methodologies across the Union.
Between 2026 and 2028, AMLA will progressively operationalise its FIU Pillar to strengthen cooperation, consistency, and effectiveness among EU FIUs. Key priorities include enabling joint analyses, embedding harmonised technical standards, and ensuring secure and efficient information exchange. A structured cycle of joint operational analyses will address cross-border typologies and emerging risks, including those linked to crypto-assets and innovative payment methods.
By 2026, AMLA’s team of FIU delegates will be fully deployed, facilitating enhanced coordination and analytical cooperation across Member States. In parallel, AMLA will implement harmonised technical standards for suspicious transaction reporting and FIU-to-FIU exchanges, issue guidelines on suspicious activity indicators by mid-2027, and further develop FIU.net to support increased data volumes and interoperability.
AMLA’s 2026–2028 programme represents a decisive turning point for Malta’s AML/CFT framework. While the reforms are EU-wide in nature, their implications for Malta are significant. The progressive harmonisation of rules, convergence of supervisory practices, and integration of financial intelligence will substantially reduce national discretion in both regulation and supervision.
In the short term, Malta is likely to experience increased compliance costs and heightened regulatory pressure, particularly for sectors such as banking, payments, gaming, corporate services, and trusts. In this regard, obliged entities should anticipate more prescriptive and standardised requirements relating to customer due diligence, beneficial ownership verification, transaction monitoring, and suspicious transaction reporting, alongside intensified supervisory engagement.
In the longer term, however, AMLA has the potential to strengthen Malta’s financial integrity, restore international confidence, and support sustainable economic development. The extent to which Maltese institutions, firms, and regulators align proactively with the evolving EU AML/CFT framework will determine whether AMLA acts as a catalyst for lasting reform or exposes persistent structural vulnerabilities.
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Author: Dr Shanise Cardona