In 2024, the European Union approved an updated regulatory framework for countering money laundering and terrorist financing (AML / CFT). This is the largest financial transparency reform in the last ten years. Although many provisions will come into force in stages, the full transition to the new requirements is scheduled for July 10, 2027. But you need to prepare for changes much earlier – businesses will need to adapt processes, structures, and documentation.
Even if the business does not operate in Europe, the changes affect everyone who:
- Conducts settlements with the EU;
- Plans transactions or investments.
- Cooperates with European banks and partners;
- Uses payment services, crypto platforms, or international structures.
The world is moving towards maximum transparency of owners and sources of funds.
What exactly is changing?
1. A single EU regulation instead of different national regulations. That is, the same requirements, without any concessions in separate jurisdictions.
2. AMLA – a new central supervisory authority that has received the following powers:
- supervise the largest and most risky financial institutions;
- conduct inspections, investigations, and apply sanctions.
- coordinate the activities of national regulators;
- monitor trans-cord operations and groups of companies.
3. EU countries are required to update their registers of beneficial owners. Companies must provide:
- full ownership structure, including indirect interests;
- data on all final beneficiaries;
- confirmation of their status and source of funds.
Complex structures, trusts, and multi-level chains are not prohibited, but they require increased transparency and documentation.
4. Tightening KYC and EDD. Mandatory subjects will conduct more in-depth checks:
- identification of the client and UBO;
- analysis of the company's structure;
- assessment of the source of funds;
- sanctions and reputational checks;
- continuous monitoring of operations.
The scope of inspections will depend on the level of risk – the regulations provide for both regular and enhanced or simplified inspections.
5. In addition to banks, the following are also subject to AMLcontrol:
Crypto services, fintech platforms, luxury and real estate companies, and electronic service providers.
6. Restriction on cash payments.
A pan-European limit is being introduced: cash payments of no more than €10,000, except in certain cases.
Companies must record transactions with large amounts of cash.
Does this affect the business of Kazakhstan, Russia and the CIS ?
Yes, even if you are not registered in Europe, the new rules also apply to you if:
- Your client in the EU;
- You attract European investment.
- You have accounts or transactions through European banks.
- You work with foreign payment providers.
In practice, this means that they will also check you as their counterargent.
While the procedure is being strengthened, the role of compliance officers is being strengthened in parallel. They are becoming the same norm for international business as an accountant or lawyer. It is responsible for:
- Correct KYC/EDD procedures.
- Risk assessment of clients and transactions;
- Analysis of the source of funds;
- Monitoring of operations.
- Work with internal policies and regulations.
What your business needs to do right now:
- The first step is to check and simplify the ownership structure.
- Prepare a complete set of beneficiary data.
- Review both your partner and customer verification procedures, and prepare a package of documents to verify you.
- Create or update an AML/CFTpolicy that reflects:
Customer identification rules.
Monitoring procedures;
Risk criteria;
And the procedure for dealing with suspicious situations. - And in general, prepare for increased attention from banks, especially in the presence of international payments, holding structures or large operations.
! You should act in advance: without transparency of the AML structure and procedureAML, the company will be perceived as risky, which in turn affects investments, transactions and access to partners.
If you need to understand what requirements will affect your business, how to prepare a package of documents, or how to properly implement a policy – we will support and develop a roadmap for applying the new rules without unnecessary bureaucracy
11.12.2025