For many organisations, this shift is likely to increase reporting obligations and requires a more proactive and judgement-based approach from compliance teams. In this blog, we highlight what is changing, who is affected, and how to prepare.
Obliged entities subject to reporting requirements
The circle of obliged entities under the AMLR is wider than under the Wwft. In addition to existing categories already, the AMLR brings new organisations into scope, including:
- managers of alternative investment funds and the funds themselves
- credit intermediaries holding funds in connection with a credit agreement
- high value goods traders
- professional football clubs and football agent
A fundamental shift: from ‘unusual’ to ‘suspicious’
Under the existing Wwft, reporting is triggered by unusual transactions. The coming AMLR replaces this with a suspicion-based reporting obligation.
This obligation arises where an institution knows, suspects or has reasonable grounds to suspect that funds or activities are the proceeds of criminal activity, are connected to terrorist financing, or are otherwise linked to criminal conduct.
Particular attention should be paid to the criterion of 'reasonable grounds to suspect'. This is broadly defined and includes not only transactions, but also activities, conduct and transaction patterns. As a result, institutions may need to identify and report suspicions of criminal involvement at an earlier stage, even without a direct link to money laundering or terrorist financing.
What needs to be reported, and when?
The reporting obligation under the AMLR is potentially wider in scope than its Wwft counterpart in three important ways.
Broader range of underlying offences
The reporting obligation applies to all criminal offences carrying a maximum custodial sentence of more than one year. A concrete predicate offence does not need to be established; a suspicion of criminal involvement suffices.
Beyond transactions
The scope explicitly covers funds and activities in the broadest sense, including attempted criminal conduct. The value or amount involved is not relevant. Even behaviour without a direct financial transaction may trigger a reporting obligation.
Focus on origin, destination and purpose
Institutions must assess not only the origin of funds, but also their destination and intended use. Legitimate funds used for a criminal purpose can therefore fall within scope. This calls for a more forward-looking and continuous approach to customer due diligence, both before and after the transaction.
Assessing suspicion
Although the AMLR does not define ‘suspicion’, the assessment must be based on all relevant facts and circumstances known to the institution, including:
- The characteristics of the client and their counterparties
- The nature, scale and patterns of the (intended) transaction or activity
- The connection between different transactions or activities
- The origin, destination or use of funds
- The consistency of the transaction or activity with the client's risk profile
Importantly, suspicions arising from an inability to complete customer due diligence are also reportable.
Reporting requirements
Reports must be submitted without delay by the designated compliance officer to the Financial Intelligence Unit (FIU). They must include a description of the suspicious situation, the parties involved and relevant amounts and transaction details.
A harmonised EU reporting format will be introduced by AMLA by 10 July 2026.
How we can support you
We support both established financial institutions and newly designated gatekeepers in preparing for and implementing these requirements. Whether you are an experienced gatekeeper adapting your existing compliance framework or a newly obliged entity building your AML infrastructure from the ground, our team works alongside you to navigate these complex regulatory changes.
If you would like to discuss what the AMLR means for your organisation or how to prepare in a timely manner, please do not hesitate to contact us or any member of our Corporate Crime & Business Integrity team.
