This week's significant developments centre on AMLA's expanding regulatory footprint: a consultation on harmonised risk assessments for the non-financial sector, a new common EU enforcement approach, and multiple draft technical standards open for comment. CySEC relayed AMLA consultations on reporting standards and regulatory technical standards under AMLD6/AMLR, while the Cyprus Bar Association circulated the annual compliance questionnaire via AMLEX-365. A proposed new EU sanctions regime targeting migrant smuggling and organised crime, plus a CySEC circular on ML/TF risks after the MiCA transitional period, also require attention.
Directly affects all non-financial obliged entities (law firms, TCSPs, accountants, etc.) — AMLA is defining common risk-assessment methodologies that will reshape how you assess and document firm-wide ML/TF risk; review and respond to the consultation before it closes.
Signals converging supervisory expectations across member states — all obliged entities should prepare for more uniform examination standards and potential direct supervisory action by AMLA from 2027.
New autonomous EU sanctions framework — once adopted, obliged entities must screen against the new designations list; monitor adoption progress and prepare to update sanctions screening procedures.
CASPs and any firm with crypto-asset clients must note updated risk guidance now that MiCA full application is in force; review CDD and risk-assessment procedures for crypto-related business.
MOKAS revised guidelines and 2025 annual report contain updated STR-filing expectations and national risk-assessment data — all obliged entities should review for changes to reporting procedures and risk-profiling.
Primary documents as published by the supervisors this week. The summary above is ours; the documents are theirs.
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