The Purpose and Limits of Anti-Money Laundering Authority (AMLA) Guidelines in Preventing Money Laundering and Terrorist Financing

Abstract

Abstract The establishment of the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) reshapes the European Union's AMLA framework, including the interpretation and supervision of its rules. This article examines the function, legal status and scope of AMLA guidelines within the new EU framework. It applies doctrinal, functional and comparative approaches to Regulation (EU) 2024/1620, Regulation (EU) 2024/1624, Directive (EU) 2024/1640, AMLA's 2026 regulatory programme and selected national practices. The analysis finds that AMLA guidelines can reduce divergent interpretations, support consistent risk assessments and strengthen cross-border supervision. Their effectiveness, however, depends on proportionality, alignment with binding technical standards, feasible implementation timelines, responsible data governance and the prevention of defensive compliance and customer de-risking. The article argues that harmonisation should not require identical procedures across sectors, but comparable, reasoned and auditable decisions. AMLA guidelines will strengthen the EU framework only if they improve risk-based decisions and measurable outcomes rather than add formal documentation. Five criteria are proposed for future guidelines: legal clarity, proportionality, operational feasibility, data accountability and outcome-based evaluation. Together with supervisory convergence and the risk-based approach, AMLA guidelines can help address the costs and consequences of money-laundering system abuses effectively.