The European Anti-Money Laundering Authority (AMLA) is finalizing 23 Level 2 + Level 3 RTS/ITS measures as the technical implementation layer underneath the EU AMLR. Most of the 23 measures are due mid-2026, with final RTS drafts submitted to the European Commission by July 2026. AMLR application date is 2027-07-10.
The practical implication for CySEC-regulated operators serving EU residents: the consultation window through mid-2026 is the last chance to shape the rules before they freeze for the July 2027 application. Operators with operational realities that diverge from the AMLR draft expectations should engage now — once RTS drafts hit the European Commission, the surface for change collapses.
Specific work AMLA is closing out in 2026 H1:
- Customer due diligence (CDD) trigger definitions at EU level (currently member-state discretion).
- Enhanced due diligence (EDD) thresholds at EU level.
- Simplified due diligence (SDD) scope at EU level.
- Risk-policy documentation standards calibrated to product mix + customer base + geographic exposure.
Operator action items:
- Run a gap analysis against the current draft AMLR + the published Level 2/3 measures. Flag operational realities that don’t map cleanly to the draft expectations.
- Submit consultation responses through the existing CySEC channel + the direct AMLA consultation process. CySEC’s circulars page tracks the live consultations.
- Re-evaluate KYC vendor procurement decisions against the AMLR’s continuous-screening + EDD threshold expectations. Vendors that today rely on member-state-specific configurations will need EU-level consistency by July 2027.
- Align internal AML training cycles + governance frameworks with the AMLR expectations now rather than scrambling in 2027 H1.
For BrokerageAtlas operators specifically, this work threads through the existing KYC + AML pre-consolidation dispatch and the Phase 4 KYC evaluation toolkit. The procurement recommendations there hold up against the AMLR draft expectations; the consultation window is the chance to influence the parts that don’t.
Source: https://www.moodys.com/web/en/us/kyc/resources/insights/a-review-of-amla-and-amlr-2026.html