FLOR🦩NCHAIN REFERENCE CARD · AMLA × CRYPTO · ED. 01 ← INDEX
FLOR🦩NCHAIN
REFERENCE CARD · 01 · COMPLIANCE DESK
FILED25 · APR · 2026 EDITORFLORIANA CLASSCHEAT-SHEET PRINTA3 · PORTRAIT CASE0xAML4 · 1620
§ AMLA × CRYPTO · ONE-PAGER FOR THE COMPLIANCE WALL

What AMLA says about cryptocurrencies, in one sheet.

Pin this above the desk. Everything a CASP compliance team needs to know about the new EU Authority for Anti-Money Laundering — sourced from AMLA, AMLR, AMLD6 and FATF R.15.
§01 · WHOFRANKFURT · DE

AMLA is the EU's first direct supervisor for high-risk financial entities.

Established by Regulation (EU) 2024/1620, AMLA opened in Frankfurt and started operations on 1 July 2025. Direct supervision of selected obliged entities begins 1 January 2028. Up to 40 entities operating in at least 6 Member States will be picked from the financial sector — explicitly including crypto-asset service providers.

§02 · WHEN2024 — 2028

Four dates that matter.

26 JUN
2024
AMLA legally exists. Regulation 2024/1620 enters force.
01 JUL
2025
AMLA goes operational. Frankfurt office; Bruna Szego appointed Chair.
10 JUL
2027
RTS for selection apply. The 40 selected obliged entities are identified.
01 JAN
2028
Direct supervision begins. AMLA exercises investigatory powers in place of NCAs.
§ DIRECTBY 2028
0
SELECTED OBLIGED ENTITIES

Across credit institutions, e-money issuers, payment institutions, and CASPs. At least one per Member State.

§ MIN. FOOTPRINTEU CROSS-BORDER
0MS
MEMBER STATES MINIMUM

An entity must operate across ≥ 6 EU Member States to qualify for direct supervision.

§ THRESHOLDAMLR · CRYPTO
0
CDD KICKS IN — OCCASIONAL TX

Customer due diligence required on any crypto transfer above this amount — including transfers to self-hosted wallets.

§ STAFFFRANKFURT HQ
~0
PROJECTED HEADCOUNT BY 2028

Today ~120; ramping to enable joint supervisory teams and on-site inspections of selected entities.

§03 · POWERSFOUR PILLARS
PILLAR 01

Direct supervision.

AMLA itself supervises 40 selected high-risk financial entities. Joint supervisory teams composed of AMLA staff + national supervisors.

REG. 2024/1620 · ART. 12
PILLAR 02

Indirect oversight.

Sets EU-wide standards, guidelines and technical standards. Reviews national supervisors' performance. Steps in as last resort if NCAs fail.

REG. 2024/1620 · ART. 30+
PILLAR 03

FIU coordination.

Operates the new FIU.net platform. Facilitates joint cross-border case analyses. Hub for the EU's financial intelligence network.

REG. 2024/1620 · CH. III
PILLAR 04

Investigatory powers.

Information requests, on-site inspections, sealing of premises, sanctions. Independent investigatory teams for serious-breach cases.

REG. 2024/1620 · ART. 21+
§03b · MISSIONSIX PRIORITIES · PROP. 2021/0240
MISSION 01

Single rulebook.

Establish one harmonised EU AML/CFT rulebook — eliminate divergent transposition across Member States.

MISSION 02

Effective implementation.

Ensure the existing EU AML/CFT framework is actually applied — not just on paper.

MISSION 03

FIU support.

Build a cooperation mechanism for Financial Intelligence Units; common reporting templates & standards.

MISSION 04

International reach.

Strengthen the international dimension of the EU framework; coordinate with FATF and third-country regimes.

§04 · WHO IS PICKED40 OF THOUSANDS

The shortlist — still being drafted.

EBA's RTS on selection criteria closed consultation 6 Jun 2025. Apply from 10 Jul 2027. Highest-risk cross-border CASPs, credit and financial institutions are likely.

EXPECTED CASP / FINANCIAL OTHER FINANCIAL ENTITY
§05 · THRESHOLDSAMLR · CRYPTO-SPECIFIC

The numbers compliance teams need by heart.

CDD on occasional crypto transfer
≥ €1,000
Travel Rule applies (originator + beneficiary info)
All transfers
Self-hosted wallet enhanced verification
≥ €1,000
EU-wide cash payment ceiling (any sector)
€10,000
Anonymous crypto accounts & privacy coins
PROHIBITED
§06 · PROHIBITEDEFFECTIVE 2027

What CASPs can no longer touch.

Anonymous crypto-asset accountsNo anonymous wallets, no anonymous custody.
Anonymity-enhancing coinsPrivacy coins (e.g. Monero) — provision & custody banned.
Anonymous safe-deposit boxesPre-existing AML rule, now harmonised.
Cash > €10,000 in business transactionsHard EU ceiling under AMLR.
§07 · TRAVEL RULEREG. 2023/1113 · IN FORCE 30 DEC 2024

What must travel with every transfer.

ORIGINATOR CASP Sender wallet Collects + sends data with txn PAYLOAD · MUST INCLUDE · Originator name · Originator address / DOB · Originator wallet ID · Beneficiary name + wallet BENEFICIARY CASP Receiver wallet Verifies + stores 7-year retention FIG. 01 — TRAVEL RULE / EU TFR · NO MIN. THRESHOLD FOR CASP-TO-CASP TRANSFERS
§08 · FATF R.15 · 2025 UPDATESOURCE — FATF JUN 2025

How the rest of the world is doing.

FATF · 2025
99jur.

Have some form of VASP regime.

Of 138 jurisdictions reviewed under Recommendation 15, 99 have introduced a VASP regulatory regime. The remainder are still drafting.

FATF · 2025
73%

Have not yet implemented Travel Rule.

Despite being a 2019 standard, most jurisdictions still lack a working Travel Rule regime — leaving the EU's December 2024 implementation a global outlier.

FATF · 2025
Stablecoins

Now the dominant illicit-finance rail.

FATF's targeted update flags stablecoins as the asset most used by DPRK actors, scammers and sanctioned entities — replacing earlier privacy-coin focus.

§09 · FUNDING MODELEU BUDGET + OBLIGED-ENTITY FEES

Who pays for AMLA.

Hybrid: a portion from the EU general budget, the rest from fees levied on obliged entities — directly or indirectly supervised. CASPs in scope of direct supervision will contribute proportionate to risk and footprint.

SOURCE · MIX
EU+ fees
Two-source funding model under Reg. 2024/1620.
2024 · BUDGET
€16m
Setup year — task force, pre-selection, IT.
2025 · BUDGET
€30m
Operations launch — Frankfurt office, ~120 staff.
2028 · STAFF
~430FTE
Steady-state for direct supervision + JSTs.