AMLR and AMLA: what changes are taking place at national level?

AMLR and AMLA are set to bring about significant changes in Europe in the coming years. There will be greater harmonisation, a single European regulatory framework and a stronger role for the European supervisory authority. This marks an important step towards greater consistency in the way anti-money laundering regulations are applied, monitored and enforced.

However, the picture is not complete if we look only at Europe. Whilst European regulations will soon form the common basis, practical implementation will continue to depend to a large extent on the choices that individual countries make. How will national supervision be organised? What powers will supervisory authorities be given? Where will responsibilities lie? And what will firms actually be scrutinised for in practice?

It is precisely at this national level that a great deal is currently happening. We asked our country managers what they are seeing in their markets. Four countries illustrate that the path towards greater European harmonisation can look very different in practice.

Spain: ANIFI consolidates power 

Spain appears to be using the European reform as an opportunity to thoroughly overhaul its national AML framework. On 28 July 2026, the Spanish government approved a bill to establish a new authority: ANIFI (Autoridad Nacional de Integridad Financiera). The aim is to bring together various tasks that are currently spread across different bodies within a single organisation. Financial intelligence, supervision, inspections and sanctioning powers would thus be brought under one roof. ANIFI is also set to become the central point of contact for the AMLA.

For the time being, however, ANIFI does not yet exist. The draft bill still has to go through several stages, including public consultation and parliamentary debate. Until then, SEPBLAC, the current Spanish supervisory authority and FIU, will remain active and the existing reporting channels will not change. If ANIFI is eventually introduced as currently proposed, it will therefore involve more than just a new name or an administrative change. It could lead to a different approach to supervision, in which the gathering of intelligence, the carrying out of checks and the taking of enforcement measures become much more closely integrated.

The key question for the coming period is therefore how ANIFI will apply the new European rules in practice. In addition, it will need to become clear how the transition from SEPBLAC to the new authority will be organised and what this will mean in practical terms for firms subject to supervision.

France: lawyers must assess themselves

France has opted for a different approach, particularly within the legal profession. The new supervision plan introduces the Diagnostic d’Évaluation Obligatoire (DEO): an annual compulsory self-assessment for all lawyers. The results of this assessment are then used as part of the supervision process. Depending on the findings, additional checks may follow, for example based on documentation or through an on-site inspection. This shifts the emphasis partly from periodic external audits to a model in which law firms and professional bodies must themselves be able to demonstrate, on a structural basis, that their AML processes are functioning effectively. It is therefore not just a question of whether policies and procedures are in place, but also whether they work in practice.

In addition, there is also a new legal obligation in France regarding training. Under the new Décret n° 2026-310, law firms must ensure that both lawyers and staff receive regular training on their AML/CFT obligations and the potential penalties for non-compliance. This obligation applies from the moment of employment and thereafter on a regular basis. Furthermore, evidence of the training undertaken must be retained and made available in the event of an audit. This makes training more than just a one-off compliance obligation. Knowledge and awareness are key factors in determining whether an AML framework is truly effective. A procedure may be well-structured on paper, but if staff do not know when and how to apply it, its practical effectiveness remains limited. This is in line with a broader trend within compliance and supervision. Supervisory authorities are increasingly keen to understand how firms assess their own risks, how they verify whether measures are effective, and how they address shortcomings.

The question, therefore, is whether this form of mandatory self-assessment, combined with a clear responsibility for training and knowledge within the firm, will remain a French development, or whether similar forms of self-assessment and ongoing monitoring will eventually play a greater role within AMLR supervision in other European countries.

The Netherlands: new responsibilities and greater powers for the FIU

In the Netherlands, one of the most concrete changes has already been implemented. Since 1 July 2026, FIU-Netherlands has been able to require institutions subject to reporting obligations to temporarily suspend a transaction where there are strong indications of money laundering, underlying offences or terrorist financing. Institutions are obliged to comply with such a request. The suspension lasts for a maximum of five working days. Where FIU-Netherlands acts on behalf of a foreign FIU, this period may be extended to a maximum of ten working days. This represents a significant expansion of FIU-Netherlands’ powers. The organisation no longer merely receives and analyses information, but can also intervene more directly in certain situations to prevent funds from disappearing before further investigation is possible.

For institutions subject to reporting obligations, this also has a practical aspect. It is not enough simply to have processes in place for detecting and reporting unusual transactions. Organisations must also be able to act swiftly and diligently when a request for suspension is received. This raises questions about internal responsibilities, decision-making and implementation. How quickly can an organisation actually act? Who is authorised to block a transaction? And are the necessary processes clearly defined, even outside normal office hours? It is precisely these kinds of practical aspects that are becoming increasingly important as regulators and FIUs are given greater powers to intervene directly.

Belgium: existing supervisory authorities stepping up their efforts

For the time being, Belgium has decided not to establish a new central authority. The main changes there relate primarily to the way in which existing supervisory authorities are preparing for the new European regulations. The Belgian supervisory authorities are already focusing heavily on the practical application of AML obligations. This includes attention to PEP obligations, national risk assessments and the implications of the new European legislation.

For Belgium, therefore, the focus is less on the question of which new supervisory authority will be established and more on how existing supervisory structures will be adapted. How can checks be carried out more consistently? Where will the priorities lie? And how will existing national practices align with an increasingly harmonised European framework? Here too, it is evident that uniform European rules do not automatically mean that supervision is organised in the same way everywhere. The legal basis is becoming increasingly European, but for the time being, practical implementation remains closely linked to national structures and choices.

The bigger picture

These four examples make it clear that the AMLR and AMLA primarily mark the beginning of a new phase. Europe is ensuring greater harmonisation and a common regulatory framework. At the same time, countries are busy preparing for this new reality in their own ways. For organisations operating in several European countries, this means that uniform implementation of AMLR is not, in itself, sufficient. The rules are becoming increasingly similar, but the way in which regulators interpret, monitor and enforce these rules may still vary from country to country. The relevant question is therefore not merely whether an organisation formally complies with AMLR. Equally important is how national supervisory authorities will apply the new rules in practice. What will they be checking? What expectations do they have of organisations? And how will it be determined whether an AML framework is actually effective? This is precisely where the next phase of AML compliance becomes interesting.

European legislation provides a common basis. However, the way in which these rules are translated into supervision and enforcement in practice will, to a large extent, become apparent at national level in the coming years. And for organisations and firms, it is precisely this combination of European harmonisation and national implementation that must be closely monitored in the coming period.