The history of anti-money laundering is characterised by devising concepts that are supposedly suitable for financial institutions (FIs) (though they fail in complying [*]), which are then transferred to all kinds of companies doing completely different things.

The recently announced Work Programme for 2025 shows that the  Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) will continue on this wrong path, even though they admit the other obliged entities are completely different, e.g. in (page 31):

In creating these mandates, the non-financial sector will be a special point of attention. The legal framework is currently significantly less harmonized in this sector compared with the financial sector.

The text “significantly less harmonized” is an understatement and shows that the AMLA neither knows nor understands the non-financial sector.

An example of the direction the AMLA is taking is found on page 47 (the annex):

An executive board member is cited with a text on a ‘unified’ framework:

“Our workstreams are defining building blocks for a unified, data-driven and resilient AML framework in Europe’s fight against financial crime.”

— Rikke-Louise Petersen, Executive Board Member, Policy Coordination

For the multitude of non-financial obliged entities, many of which are SMEs, things look bad. They are likely to go down with fines and other penalties for not complying properly with the “unified” AML rules

Note:

[*] Not because they don’t want to comply, but because the rules are unworkable.