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EstoniaRahapesu Andmebüroo

Estonian FIU tells obliged entities how to prepare for AMLA

New FIU guidance on AMLA's instruments and supervision: name someone to track the drafts, assess their effects on internal rules, and join the consultations.

By Taxxa AI OyPublished 10 September 2026

Financial Sector & Markets

Industry: Financial and insurance activities

Estonia's Rahapesu Andmebüroo has added a new section to its supervision pageFIU explaining how the EU Anti-Money-Laundering Authority (AMLA) and its regulatory instruments may affect Estonian obliged entitiesFIU. Regulation (EU) 2024/1624 sets directly applicable anti-money-laundering requirements that obliged entities must follow in their activitiesFIU. Everything else on the page — who is supervised, the legal framework, the inspection procedure, data protection, closing an inspection and appeals — is unchanged apart from presentation: collapsed accordions, a corrected RSanS abbreviation and the new 10.09.2026 update stamp.

AMLA, created in 2024, works toward more uniform application of AML/CFT requirements, harmonised supervisory practice and stronger cooperation between national authorities. Its three lines of work are direct supervision of selected financial-sector obliged entities, development of regulatory instruments and support for cooperation between national supervisors and financial intelligence units. Its Executive Board runs day-to-day management; its General Board, with representatives of every Member State competent authority, works in two compositions — an FIU composition for intelligence-unit cooperation and a supervisory composition for the supervision system — with a Standing Committee under the FIU composition that has no decision-making power of its own. The Estonian bureau's head sits on the General Board and co-chairs the FIU composition's Standing Committee, and since spring 2026 an Estonian national delegate supports AMLA processes.

AMLA develops draft regulatory technical standards (RTS)FIU and implementing technical standards (ITS)FIU and issues guidelines and recommendationsFIU. Standards adopted by the Commission are bindingFIU and apply under the arrangements in the applicable EU actsFIU; guidelines and recommendations are generally not legally bindingFIU but shape supervisory practiceFIU and describe what AMLA and competent authorities expectFIU. Instruments already published or put to consultation cover business-wide risk assessments, customer due diligence, ongoing monitoring, criteria for identifying linked transactions, group-level AML/CFT controls, formats for suspicious transaction and activity reports and information exchange between authoritiesFIU. A draft put to public consultation may change during the procedureFIU and is not a requirement in force before final adoptionFIU — but reading it early leaves time to assess its impact and plan changes.

From 2028 AMLA directly supervises only selected cross-border higher-risk financial-sector obliged entities and groupsFIU; other financial-sector entities stay under national competent authoritiesFIU. Exceptionally, AMLA may also take a non-selected financial-sector entity under direct supervision on the conditions in the governing act. It does not directly supervise non-financial-sector entities, though its work may affect what supervisors expect of them. In Estonia an obliged entity generally keeps dealing with its own competent authorityFIU, and suspicious transaction and activity reports still go to Rahapesu AndmebürooFIU.

For dealing with the new instruments, the bureau recommends that each obliged entity name a person or unit to follow AMLA instruments and consultationsFIU; assess whether published or planned standards, guidelines and recommendations affect its risk management, customer-knowledge or monitoring processesFIU; examine whether consultation documents on risk assessment, due diligence or ongoing monitoring require changes to internal rules or controlsFIU; follow consultations and notices to catch future changes earlyFIU; plan IT, data-collection or reporting changes where drafts add data requirements or standardised formatsFIU; update training and working instructions after final adoptionFIU; and take part in consultations directly or through professional associationsFIU.

Legal basis: the new AMLA section on the Rahapesu Andmebüroo supervision page, with references to Regulation (EU) 2024/1624, Regulation (EU) 2024/1620 Articles 49 and 53–55, and RahaPTS §§ 49, 54 and 64; the page was last updated on 10.09.2026.

Name a person or unit to track AMLA instruments and consultations, and work through the bureau's preparation list against internal rules and controls.

Sources

Järelevalve