1. Market expectations

Some see it as a bureaucratic ‘monster’, a symbol of the ever-tightening anti-money laundering regulations, first in the banking sector and then in other sectors. Nevertheless, the roll-out of Amla is proceeding as planned. The European Union Agency for Combating Money Laundering and Terrorist Financing, based in Frankfurt, is set to reach full operational capacity in 2028. Its mission is to strengthen and harmonise the supervision of anti-money laundering rules within the EU.

In Luxembourg, there is a belief that European harmonisation will help to create a more level playing field between Member States. The deputy CEO and general counsel of ALFI, Corinne Lamesch, believes that the country has a head start: “Luxembourg already applies very high standards in the fight against money laundering. We are therefore not concerned about the stringency of future rules, as most of these standards are already in place here.”

On the banking side, ABBL legal advisor Amandine Laurent calls for “turning Amla into an opportunity”. Whilst its implementation raises questions, particularly regarding the timetable and the operational burden, “this new framework also marks the start of a collective learning process”, she insists.

The ABBL works closely with the CSSF, which sits on Amla’s working groups, to influence the drafting of technical standards ahead of the consultation phases. “Now is the right time to re-examine certain approaches and ensure that the mechanisms in place remain fully aligned with their primary objective: the effective reduction of financial crime,” notes Amandine Laurent. In this context, the ABBL advocates for greater alignment with the standards of the Financial Action Task Force (FATF).

2. Banks

For Luxembourg banks, the introduction of Amla highlights a key issue: the effective calibration of the risk-based approach. The ABBL emphasises the need to give clear operational substance to the concept of proportionality, which is often invoked but still applied inconsistently.

Another key issue is the exchange of information, particularly in the context of the intensified fight against fraud. Faced with increasingly rapid and sophisticated fraud schemes, institutions are seeking to strengthen information sharing in order to take action in real time and limit losses. However, such exchanges remain constrained, notably by the General Data Protection Regulation (GDPR) and by professional secrecy rules, which strictly regulate the circulation of certain data. In this context, the ABBL is exploring solutions compatible with the current framework, including through regulated mechanisms or forms of enhanced cooperation with the authorities.

Effective supervisory dialogue will be essential.

Corinne Lamesch, deputy CEO et general counsel, One thousand

3. Asset management

For the fund industry, the main challenge is to ensure that future European rules are not modelled purely on the banking sector. Alfi points out that the very structure of fund distribution differs significantly from that of the banking sector. “The fund industry is highly intermediated: when an investor wishes to buy a fund, they do not usually deal directly with the fund itself, but go through their bank, a distributor, a broker or an investment platform,” explains Corinne Lamesch.

In most cases, it is this intermediary who maintains the direct relationship with the end client, which makes certain obligations difficult to enforce. “Some regulations stipulate, for example, that one can ‘look through’ the intermediary to identify the end investor,” notes the deputy CEO. In practice, she believes, such an approach “would entail considerable and unjustified costs”. If a regulated financial intermediary – such as a bank – already carries out the necessary checks on the end investor, the requirement for systematic look-through does not appear relevant in Alfi’s view.

Beyond these technical aspects, the industry regrets that administrative simplification is not among the stated priorities of the future European authority. Industry players see digitalisation as a key driver for more effective implementation of regulatory obligations. “Digitalisation has become essential in the fight against financial crime, as criminals themselves are using increasingly sophisticated technologies,” notes the Alfi representative. Customer identification procedures could thus be significantly modernised using existing digital solutions.

Finally, the association highlights the need for the future authority to possess sound sector-specific expertise. Alfi encourages Amla to recruit asset management specialists to ensure that supervision does not become too detached from the operational realities on the ground. “In short, effective supervisory dialogue will be essential,” concludes Corinne Lamesch.

This article was written for the Asset Management supplement of Paperjam magazine’s May 2026 issue, published on April 29. The content is produced exclusively for the magazine. It is published on the website to contribute to Paperjam’s comprehensive archive. Click on this link to subscribe to the magazine.

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