The New EU Anti-Money Laundering Authority (AMLA) and the Standard for the Application of National Laws: ‘What’s Past Is Prologue’?

This paper aims to examine the limits and methods governing the interpretation and application of national laws by the new European Union Anti-Money Laundering Authority (AMLA) under Article 5(6) of the AML Regulation (AMLAR). It first analyses how the EU’s novel supervisory system for anti-money laundering and countering the financing of terrorism (AML/CFT) may differ from previous institutional models, and, in particular, from the Single Supervisory Mechanism (SSM). It then explores whether, and how, the Court of Justice of the European Union (CJEU) case law on Article 4(3) of the SSM Regulation (SSMR) should apply to AMLA.