The European Union (“EU”) has entered a new phase in anti-money laundering and counter-terrorist financing (“AML/CFT”) regulation with the introduction of the new EU AML legislative package, representing the most substantial reform of the European AML/CFT framework in recent decades. The package is principally composed of Regulation (EU) 2024/1624 (commonly referred to as the “AMLR”), Regulation (EU) 2024/1620 establishing the Anti-Money Laundering Authority (“AMLA”), and Directive (EU) 2024/1640, widely referred to as the Sixth Anti-Money Laundering Directive (“AMLD6”).
The legislative package was officially published in the Official Journal of the European Union in June 2024 and is designed to establish a unified EU AML/CFT regime based on a single rulebook, enhanced supervisory convergence and centralised European coordination mechanisms. Unlike previous AML directives, the AMLR will apply directly across all EU Member States without the need for national transposition. The regulation will become fully applicable from 10 July 2027 and is expected to significantly reduce the historical fragmentation that has characterised AML/CFT implementation across the EU.
AMLA: Structure and Supervisory Architecture
A central feature of the reform is the establishment of AMLA, headquartered in Frankfurt am Main. AMLA formally commenced operations on 1 July 2025, and its supervisory and coordination functions are being phased in progressively. On 1 January 2026, the European Banking Authority completed the transfer of its AML/CFT mandates to AMLA, further consolidating the European supervisory architecture. From January 2028, AMLA is expected to assume direct supervision of selected high-risk cross-border financial institutions, while exercising indirect oversight over national competent authorities through common supervisory methodologies, Regulatory Technical Standards (“RTS”), guidelines and coordination procedures.
Implications for the Maltese Financial Services Sector
For Malta, these developments are particularly significant given the jurisdiction’s extensive international financial services ecosystem, including investment services, fund administration, trusts and fiduciary structures, corporate service providers (“CSPs”), remote gaming, maritime structures and digital assets activities. Malta’s regulatory evolution over recent years, including reforms implemented following the Financial Action Task Force enhanced monitoring process, has substantially strengthened the jurisdiction’s AML/CFT supervisory architecture and compliance infrastructure.
This strengthening has been particularly visible through the coordinated work of the Malta Financial Services Authority (“MFSA”) and the Financial Intelligence Analysis Unit (“FIAU”), particularly in areas involving Ultimate Beneficial Ownership (“UBO”) transparency, Customer Due Diligence (“CDD”), Source of Wealth and Source of Funds verification, risk-based supervision and ongoing compliance monitoring. Malta’s implementation of central UBO registers and increasingly sophisticated governance and internal control expectations reflects the broader European regulatory trend towards transparency, accountability and supervisory harmonisation.
Operational Impact on Maltese Obliged Entities
The practical implications of the AMLA framework for Malta-based operators are expected to be considerable. Financial institutions, Crypto-Asset Service Providers (“CASPs”), trustees, fund administrators and CSPs operating on a cross-border basis within the EU may become subject either to direct AMLA supervision, where falling within the scope of selected obliged entities, or to supervisory expectations and technical standards increasingly influenced by AMLA guidance and coordination mechanisms.
This development is particularly relevant for Malta’s digital assets sector, where AML/CFT obligations are increasingly intersecting with the Markets in Crypto-Assets Regulation (“MiCA”) and the revised Transfer of Funds Regulation, including the implementation of the so-called Travel Rule requirements applicable to crypto-asset transfers. Regulated entities are expected to face heightened governance expectations at board and senior management level, particularly regarding transaction monitoring, sanctions screening, outsourcing controls, data governance, compliance reporting and internal audit effectiveness.
Supervisory Convergence and Strategic Outlook
The new framework places substantial emphasis on supervisory convergence between EU Member States. Historically, AML/CFT compliance across the EU has been characterised by differing national interpretations and varying degrees of supervisory intensity. The AMLR and AMLA framework seek to reduce these inconsistencies through a more centralised European supervisory methodology applicable across all jurisdictions, including Malta. Industry participants are therefore increasingly preparing for a more technology-driven, data-intensive and compliance-focused regulatory environment ahead of the 2027 implementation phase.
From a Maltese regulatory perspective, the reforms are unlikely to diminish the jurisdiction’s role as an international financial centre. On the contrary, the new framework is expected to reinforce Malta’s positioning as a mature, highly regulated European financial jurisdiction operating within an increasingly harmonised EU supervisory structure. As the AMLR becomes fully applicable from July 2027 and AMLA progressively expands its operational and supervisory role, Malta is expected to remain strategically relevant within the evolving European financial governance and AML/CFT landscape, particularly in sectors involving cross-border financial services, investment structures, fiduciary services and digital assets regulation.
How Promethean Can Assist
Promethean advises financial institutions, CSPs, trustees, fund administrators and CASPs operating in or from Malta on the implications of the AMLR, AMLD6 and the AMLA supervisory framework. Our team supports clients in conducting AML/CFT gap analyses against the new single rulebook, reviewing governance and internal control frameworks, preparing for the transition period ahead of 10 July 2027, and engaging with the MFSA and the FIAU on regulatory expectations. For further information on how the EU AML reform package may affect your operations, please contact us.
