EU-AML Countdown: What Matters Now

Time is running out: With the new EU anti-money laundering package, sweeping regulatory changes are on the horizon for companies across Europe. The implementation deadline of 2027 may seem distant, but the requirements are complex, multilayered, and demand targeted preparation today. In a German-language webinar attended by over 50 professionals from banking, fintech, payments, and consulting, experts from Sinpex and Annerton shared practical insights on the current status, upcoming obligations, and recommended actions.

Status Quo: New Authorities, New Requirements

Sebastian Glaab (Annerton) outlined the current regulatory landscape. With the adoption of the new EU AML Regulation (EU 2024/1624), it’s clear that European anti-money laundering policy is being centralized and reinforced. The newly established EU authority AMLA, based in Frankfurt, will directly supervise major market players and increase pressure on national regulators.

What’s new: the integration of topics like financial sanctions and a stronger focus on corporate accountability. Glaab cautioned, “Many technical standards are still pending, but what’s already clear is that documentation and evidence requirements will increase significantly.”

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Pain Points: Why Excel Is No Longer Enough

Camillo Werdich (Sinpex) shared an eye-opening perspective from the field: “Many companies still rely on Excel and CRM systems without standardized data models. That won’t be sufficient going forward.”

Particularly critical: identifying ultimate beneficial owners (UBOs). BaFin clarified in its guidance (Nov. 2024, Section 5.2.3.2) that solely using third-party sources like databases or credit agencies is no longer acceptable. Primary sources such as commercial registers and shareholder lists are required.

Another major issue: the lack of automation, which hampers auditability, traceability, and evidence-building.

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Requirements by 2027: Act Strategically

A risk-based approach, shorter review cycles, a new division of responsibilities between AMLA and national regulators—the list of requirements is long.

Glaab recommended conducting a structured gap analysis and updating the “documented internal control system.” The expected workload is substantial, as shown in a live poll during the webinar:

How much additional workload is expected due to the EU AML package?
• 64% expect 10–50% more workload
• 25% foresee 50–90% more workload
• Only 7% expect no significant increase

Werdich emphasized the strategic relevance: “Compliance is becoming a competitive factor. Companies that invest in scalable processes today will be better prepared tomorrow.”

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Practical Perspective: The Key Role of Evidence

A central keyword of the webinar was evidence—the verifiable traceability of all AML-relevant processes. Article 55 of the EU AML Regulation requires that all relevant information be documented in a way that enables full reconstruction during audits or investigations.

As Werdich put it: “Without clean data management, centralized systems, and automated documentation, compliance won’t be achievable.”

Participant polling also revealed strong patterns:

How well prepared do participants feel for the new AML package?
• 68% answered “partially prepared”
• 14%: “not well prepared”
• 18%: “fairly well prepared”

What is the biggest current challenge in the AML process?
• 40%: Technical adaptation of existing systems
• 20%: Documentation and evidence
• 17%: UBO identification
• 13%: Risk assessment
• 3%: Deadline and cycle management

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Conclusion: The Time to Act Is Now

Thinking “there’s still time until 2027” may prove to be a mistake. Experts agreed: now is the time to identify gaps, adapt processes, and assign responsibilities internally.

The webinar made it clear: the challenges are significant, but with the right mix of legal clarity, technological support, and internal alignment, compliance risks can be transformed into competitive advantages.

Further information on the implementation of the EU AML package and the German-language webinar recording can be found here.

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