ARTICLE
25 June 2026

AML-CTF Package: Gear Up Now

CL
CMS Luxembourg

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The EU Anti-Money Laundering Regulation introduces a harmonised regulatory framework across the European Union, bringing significant changes to Customer Due Diligence requirements and risk-based approaches. Organizations will need to review their compliance frameworks to meet new obligations on customer identification, beneficial ownership, sanctions screening, and risk assessment ahead of implementation.
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The EU Anti-Money Laundering Regulation (AMLR), introduced under the AML-CTF Package, marks a major step towards a more harmonised and consistent regulatory landscape across the European Union.

This series highlights the key changes, with a focus on Customer Due Diligence (CDD) requirements and the strengthened risk-based approach (RBA). The new framework introduces more detailed obligations on customer identification, beneficial ownership, sanctions screening, and risk assessment, while clarifying the application of simplified and enhanced due diligence measures.

These developments will require organisations to review and adapt their compliance frameworks to ensure readiness ahead of implementation.

AML-CTF Package: preparing for the new EU framework

The EU Anti-Money Laundering and Counter-Terrorist Financing (AML-CTF) package is composed of four legislative texts, all of which aim at harmonising and strengthening AML-CTF rules across the European Union.

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Customer Due Diligence measures – Key changes you need to know

The Anti-Money Laundering Regulation (AMLR) introduces several important changes to Customer Due Diligence (CDD) requirements. These updates expand the scope of trigger events, deepen the level of information required, and reinforce compliance obligations for obliged entities.

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Risk-based approach : key updates

Under the AMLR, the fundamental principle remains unchanged: the Risk-Based Approach (RBA) continues to sit at the core of the AML-CTF framework. The objective is clear. AML-CTF measures must be proportionate and tailored to the specific risks of money laundering and terrorist financing identified in each situation.

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New limit to large cash payments and prohibition of anonymous instruments

The Anti-Money Laundering Regulation (AMLR) introduces several important measures aimed at reducing risks linked to anonymity and large cash transactions within the European Union. These changes affect both market practices and compliance obligations for certain categories of professionals.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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