AMLR 2027 gap assessment: what changes for your institution?

The EU Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624) will apply from 10 July 2027. It replaces a large part of national anti-money laundering and counter-terrorist financing rules with a single rulebook, directly applicable throughout the European Union.

For many institutions, the question is no longer whether their framework needs to change, but where, in what order and with what resources. That is exactly what the assessment is for.

Who is it for?

The assessment is designed for entities subject to AML/CFT obligations, in particular

• banks and credit institutions;

• payment and e-money institutions;

• crypto-asset service providers (CASPs);

• insurance companies and relevant intermediaries;

• asset managers and other obliged financial firms.

It is especially useful if your institution is growing, operates in several European countries, or if your last inspection identified areas for improvement.

What the AMLR changes in practice

Without being exhaustive, the regulation reshapes several pillars of your framework.

• Customer due diligence, with harmonised, more detailed rules and stronger identification and verification requirements.

• Beneficial ownership, with clarified identification rules, in particular for complex structures.

• Governance, with clearer responsibilities for senior management and the compliance function.

• Group policies, with stronger requirements for groups and cross-border activities.

• AMLA technical standards, as the new EU Anti-Money Laundering Authority progressively publishes standards and guidelines that specify how the regulation applies.

Each of these points can directly affect your procedures, tools, controls and staff training.

How the assessment works

1. Scoping. An initial call to understand your business, organisation and priorities, and to agree on the relevant scope.

2. Gap analysis. Review of your existing framework (procedures, risk assessment, customer due diligence, tools, controls) against the requirements of the AMLR and the AMLA texts published so far.

3. Prioritisation. A clear map of the gaps, ranked by regulatory criticality and the effort needed to close them.

4. Roadmap to 10 July 2027. A concrete, sequenced action plan, realistic given your resources, which you can run internally or with support.

You receive an assessment report, the map of prioritised gaps, the roadmap and a debrief with your teams and senior management.

What drives the scope

Every institution is different. The scope of the assessment depends in particular on

• the size, activities and products of the institution;

• the maturity of the current AML/CFT framework;

• the availability and state of existing documentation;

• the number of entities, countries or business lines involved;

• the tools in place (screening, scoring, transaction monitoring).

This is why each engagement is based on a fixed-fee proposal built after the scoping call, tailored to your context. You receive it within 48 hours of our call.

Why Studio Compliance

• 25 years of experience in compliance and financial crime prevention, across traditional banking and fintech.

• CAMS certified (Certified Anti-Money Laundering Specialist) and board member of the ACAMS France Chapter.

• Hands-on experience of remediation under regulatory pressure and of working with supervisory authorities.

• A pragmatic approach, with actionable, prioritised and auditable recommendations.

Frequently asked questions

Who is affected by the AMLR?

All entities subject to anti-money laundering and counter-terrorist financing obligations in the European Union, including credit, payment and e-money institutions, crypto-asset service providers, insurers, asset managers and other regulated professions.

What happens on 10 July 2027?

The AMLR becomes applicable. Its requirements apply directly to institutions, without national transposition.

Should we wait for all AMLA technical standards before starting?

No. Many requirements are already known. Starting early helps identify the longest workstreams (tools, data, group procedures) and incorporate AMLA's clarifications as they are published.

Does the assessment replace an audit?

No. It is an action-oriented gap analysis that gives you a clear view of what needs to change and in what order. It can serve as the basis for a compliance plan or a later audit.

Can you support the implementation?

Yes. The roadmap can be run internally or with support from Studio Compliance, depending on your needs.

How do we get started?

With an initial scoping call, with no commitment, to assess your situation and the relevant scope.

Prepare for July 2027 with confidence

An initial scoping call is the best way to review your situation and define the next steps. Write to contact@studio-compliance.com or use the contact form.