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For whom

MLRO

The new EU AML package, the Travel Rule and the sanctions environment in one view — every AMLA guideline, every EBA guideline, every TFR clarification classified and routed to your AML team on the day it is published. So your programme is AMLA-ready before direct supervision begins.

As of:

Your reality

You own the AML/CFT programme — and the entire legal framework is being swapped out: the single rulebook of the AMLR, the new EU authority AMLA, the Travel Rule for crypto transfers, sanctions screening, and CASPs joining as obliged entities. The single rulebook, the AMLA guidelines and the EBA guidelines are being published layer by layer over the coming quarters. Miss a change and you calibrate your programme against outdated law — just as a new authority prepares to supervise it directly.

01Your week as an MLRO

Monday. Alert review and the SAR pipeline. In between, the question of whether the latest EBA due-diligence guideline or a new sanctions listing touches your screening rules — and whether the Travel Rule data flows with foreign counterparty CASPs are still clean.

Tuesday through Thursday. In parallel: migrating the programme to the AMLR single rulebook (application from 10 Jul 2027), building the CASP obliged-entity onboarding processes, and reconciling the Travel Rule verification for self-hosted wallets under Art. 14(5) against the EBA guidelines (EBA/GL/2024/11). Three open work-streams, three deadlines.

Friday. Report to management and AMLA-readiness preparation. The honest question: does your programme reflect the current state of the unfolding single rulebook — or the state your team last happened to catch?

02What changes for your role in 2026/2027

The AML package takes hold. The AMLR (Regulation (EU) 2024/1624) brings a directly applicable single rulebook — applicable from 10 Jul 2027 — with harmonised due diligence, an EU-wide EUR 10,000 cash limit and a 25% UBO threshold. AMLD6 (Directive (EU) 2024/1640) replaces the national frameworks [1].

AMLA becomes operational. The new Anti-Money-Laundering Authority (Regulation (EU) 2024/1620), seated in Frankfurt, is building its structures and begins direct supervision of selected high-risk obliged entities from 2028. Its guidelines and technical standards are published continuously until then — and shape how your programme is assessed [2].

Crypto moves to the centre. CASPs are obliged entities under the AMLR from 10 Jul 2027; in parallel, the Travel Rule (Regulation (EU) 2023/1113) already requires transmission of the transfer data with no de-minimis and a verification of ownership for self-hosted wallets above EUR 1,000 — refined by the EBA guidelines EBA/GL/2024/11 [3].

03What your management actually wants to see from you

Management wants a defensible AML programme that demonstrably follows current law — and that survives a direct AMLA inspection. With the enforcement focus shifting to Europe and sharply higher penalty sums, the uncomfortable reality is: the most expensive gap is the one nobody knew was open.

That presupposes a complete regulatory detection layer. An AML programme cannot rest on a guideline the team never saw — and in the AMLA era, the evidence of when a requirement was detected and implemented becomes an inspection item in itself.

What changes

Six tasks Horizon Scanner takes off your desk

Concrete mechanics against the five friction points of your week. Each item is live in the tool — not on a roadmap.

  • 01

    Track the AML package and the single rulebook

    The AMLR (Regulation (EU) 2024/1624), the AMLA Regulation (EU) 2024/1620 and AMLD6 (Directive (EU) 2024/1640), plus the downstream AMLA guidelines and EBA guidelines, all run through the same capture. Every new layer of the single rulebook is detected and assigned to the AML function instead of disappearing into the inbox.

  • 02

    Keep the Travel Rule and sanctions environment current

    Changes to the TFR (Regulation (EU) 2023/1113), the EBA Travel Rule guidelines (EBA/GL/2024/11) and the sanctions-screening environment are captured and routed to the AML/sanctions team — so the self-hosted-wallet verification and the screening follow the current rules.

  • 03

    Cover the CASP obliged-entity duties

    For crypto-asset service providers, Horizon Scanner monitors the interlocking regimes — AMLR (obliged entities from 10 Jul 2027), MiCA and TFR — and tags which finding touches which duty, so no cross-reference between the frameworks is lost.

  • 04

    Route to AML, sanctions and onboarding

    Pre-configured routing rules: due-diligence changes to the KYC/onboarding team, sanctions listings to the screening team, CASP-specific topics to crypto compliance. Defaults are in place from day one; every rule is editable.

  • 05

    Document AMLA readiness in audit-ready form

    Every capture, classification and routing decision is logged immutably, 5 years, CSV/JSON export. When AMLA or the national FIU asks since when a requirement was known and how it was implemented, the answer is objectively evidenced.

  • 06

    Keep the enforcement trend in view

    Beyond the legal texts, Horizon Scanner captures supervisory priorities and enforcement signals — where authorities are currently inspecting, which topics lead to penalties. This lets the programme align to actual supervisory practice, not just the letter of the law.

The numbers your board sees

Translated from compliance language into board language.

  • < 4 hours

    Median time from supervisory publication to a confirmed entry at the responsible AML team.

  • ≥ 90 %

    Day-one default routing accuracy — the share of findings reaching the right AML/sanctions function without manual correction.

  • 5 years

    Immutable audit-trail retention — matches the AMLA and FIU documentation expectation of the programme.

  • 0 FTE

    Additional headcount per new rulebook in your scope. The detection layer scales through technology, not headcount.

Questions you will ask

  • Do you screen our transactions or customers?

    No. Horizon Scanner is not a transaction-monitoring or screening system and processes no customer or payment data. We monitor the regulatory rules — AMLR, AMLA guidelines, TFR, sanctions frameworks — and ensure your screening and KYC setup follows the current state. The monitoring of your transactions stays with your existing systems.

  • How does this help with AMLA readiness?

    We capture the AMLA guidelines and technical standards as they are published, classify their impact and route them to the responsible AML function — plus an auditable trail of when you became aware. So your programme follows the unfolding single rulebook rather than chasing it once direct supervision begins.

  • Do you cover the Travel Rule and self-hosted wallets?

    Yes. We track the TFR (Regulation (EU) 2023/1113) and the EBA guidelines EBA/GL/2024/11 — including the ownership verification for self-hosted wallets above EUR 1,000 and the handling of missing originator/beneficiary data. Changes to these rules are detected and routed to your crypto-AML team.

  • Are we even in scope as a CASP?

    For crypto-asset service providers the scope is especially dense: AMLR obliged entities from 10 Jul 2027, MiCA duties, TFR from the first cent. Horizon Scanner monitors these regimes in parallel and tags every finding by the framework it affects — so a cross-reference (e.g. between MiCA market abuse and AML duties) is not lost between two teams.

Sources

  1. [1]AMLR — Regulation (EU) 2024/1624 + AMLD6 — Directive (EU) 2024/1640 — EUR-Lex
  2. [2]AMLA — Regulation (EU) 2024/1620 (seated in Frankfurt, direct supervision from 2028) — EUR-Lex
  3. [3]TFR — Regulation (EU) 2023/1113 + EBA Travel Rule guidelines (EBA/GL/2024/11) — EUR-Lex / EBA

Let's walk through the reality of your week.

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