One year to go: a twelve-month plan to 10 July 2027
With twelve months left before the AMLR applies, a quarter-by-quarter plan for an obliged entity: gap analysis, design, build, test, and the evidence supervisors will want to see on day one.
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Twelve months before the AMLR applies is late for a start and early for a finish. Most of the Level-2 texts exist in final draft, the first RTS are with the Commission, and the remaining Guidelines are in consultation. That is enough certainty to plan against. Here is a plan in four quarters for an obliged entity of moderate size.
Quarter 1 (July to September 2026): know your gaps
- Complete the gap analysis block by block against the compliance framework, not article by article; the framework view shows where several instruments land on the same process.
- Decide the governance: compliance manager appointed, programme owner named, board reporting cadence fixed.
- Classify every AML task performed by a vendor or group entity as prohibited, outsourcing, reliance or technology.
- Respond to the open consultations that matter to you: the STR template, the business-wide risk assessment, ongoing monitoring.
Quarter 2 (October to December 2026): design
- Customer data model aligned with the CDD RTS and the STR template; one change serves both.
- Beneficial-ownership method: 25% threshold, control through other means, layered structures, discrepancy reporting.
- Risk classification and review frequencies aligned with the draft Guidelines; expected transaction profile made structured.
- Reporting process redesigned around suspicion, with the template as the target output.
Quarter 3 (January to March 2027): build and re-verify
- Start the re-verification wave for customers whose beneficial-ownership data or risk classification does not meet the new rules, highest risk first.
- Implement the twelve-month PEP clock, the HNWI classification and the sanctions screening of beneficial owners.
- Repaper outsourcing and reliance agreements.
- Train staff and the management body; record it.
Quarter 4 (April to June 2027): test and evidence
- Dry-run the STR template on real cases; test the event-driven review end to end.
- Independent review of the programme by the internal audit function or an external party.
- Assemble the evidence pack: risk assessment, policies, appointments, minutes, training records, remediation status.
- Board sign-off before 10 July 2027, with the residual items and their dates.
After 10 July 2027
Compliance becomes a standing cycle: periodic reviews, register checks, reporting on the template, and the next AMLA guidelines. The workspace of AMLR Monitor turns this plan into a readiness tracker with owners, target dates and a board report.