AMLA in November 2026: current duties, future scope and practical priorities

Three statuses with different effects

As at 12 November, AMLA’s tracker, updated on 10 November, lists final reports on draft RTS for CDD, occasional and linked transactions and third-country group requirements. It records closed consultations for the central database, ongoing monitoring and business-wide risk assessment. The consultation on draft ITS for the format for reporting suspicions and providing transaction records (Article 69(3) AMLR) is also closed. Check each instrument’s adoption, publication and application date.

The applicable national and sectoral rules remain the starting point today. Regulation (EU) 2024/1624 has been adopted and generally applies from 10 July 2027. The football categories follow the deferred date of 10 July 2029.

The sector label is only a starting point

Under AMLR, real estate intermediation includes letting where monthly rent is at least EUR 10,000, irrespective of payment method. Cultural goods traders or intermediaries and relevant activities in free zones or customs warehouses have distinct conditions, including EUR 10,000 or more across linked transactions. For high-value goods, check Annex IV and whether the activity is regular or the principal professional activity.

Also check crowdfunding services, certain credit intermediaries, investment migration operators and non-financial mixed activity holding companies. For professional football clubs, examine transactions with investors, sponsors and intermediaries, and player transfers. A national exemption for top-division clubs requires proven low risk and turnover below EUR 5 million in each of the prior two calendar years.

Prepare an initial review

For each activity record the jurisdiction, actual service, authorisation, transaction type, threshold and relevant date. Separate controls already required from changes to plan, with an accountable owner and evidence for each item.