Effective June 19, 2024 · Published May 6, 2026
EU AMLA & AML Package: What Family Offices Must Know
The European Union's 2024 AML Package, comprising a new Anti-Money Laundering Regulation (AMLR), a revised Anti-Money Laundering Directive (AMLD6), and the regulation establishing the Anti-Money Laundering Authority (AMLA), represents the most significant overhaul of EU AML/CFT rules in over a decade. Published in the Official Journal in June 2024, the package creates a single EU rulebook that will apply directly across member states without needing national transposition for the regulatory core, and establishes AMLA as a centralised supervisory body headquartered in Frankfurt.
For family offices, the critical shift is an expanded definition of 'obliged entities.' Wealth managers, asset managers, and certain investment-related structures serving high-net-worth clients are explicitly drawn into scope. AMLA will directly supervise the riskiest cross-border financial entities from around 2028, while national competent authorities will oversee others under harmonised standards. Beneficial ownership rules are tightened, enhanced due-diligence requirements for high-risk clients and transactions are standardised EU-wide, and member states retain limited discretion to gold-plate rules, reducing regulatory arbitrage that some structures previously exploited.
Who is affected
- Family offices providing investment management, wealth structuring, or financial advisory services to members of a family or third parties, particularly those operating across multiple EU jurisdictions
- Holding structures, trusts, and foundations through which family wealth is held, to the extent they fall within the expanded obliged-entity or beneficial-ownership disclosure perimeter
- Family offices currently relying on national-level AML exemptions or lighter-touch regimes that may be narrowed or eliminated under the harmonised single rulebook
Key changes
- A directly applicable EU AML Regulation replaces the patchwork of national implementations, standardising customer due diligence, beneficial ownership verification, and suspicious transaction reporting obligations across all member states
- AMLA gains direct supervisory authority over a defined set of high-risk, cross-border obliged entities; indirect influence on all obliged entities intensifies through binding regulatory and implementing technical standards issued to national supervisors
- Beneficial ownership thresholds and look-through requirements for complex legal arrangements (including trusts and similar structures) are tightened, and interconnected EU-wide beneficial ownership registers are to be further integrated
Recommended action
Family offices should immediately map every EU-nexus entity and account relationship against the expanded obliged-entity definition in the AMLR to determine whether direct obligations apply, and commission a gap analysis of existing AML/CFT policies against the new single rulebook. Engage legal counsel familiar with both AMLA's draft technical standards and the relevant national competent authority's implementation timeline, as transitional provisions and AMLA's direct supervisory perimeter will phase in over several years ahead of the approximately 2027-2028 operational target.
Sources
- [1]Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLR)— Official Journal of the European Union / EUR-Lex
- [2]Regulation (EU) 2024/1620 establishing the Anti-Money Laundering Authority (AMLA)— Official Journal of the European Union / EUR-Lex
- [3]Anti-Money Laundering Authority — Official Website— AMLA
- [4]Anti-Money Laundering and Countering Financing of Terrorism Legislative Package— European Commission