Part 3 of 6 in our series on the compliance lessons from the FIU Annual Report 2025.
10 July 2027 may seem a long way off. It isn’t. The FIU Annual Report 2025 shows that preparations for the new European anti-money laundering framework are already well underway. AMLA has started operating, European guidelines and technical standards are being developed, and FIUs are preparing their processes for greater cooperation, standardisation and faster information exchange.
The acting head of FIU-Netherlands calls this development one of the biggest transitions of recent years for good reason. In this blog, we look at what will change towards 2027 and what this means for KYB.
What will change by 10 July 2027?
The FIU Annual Report outlines a clear timeline. The European Anti-Money Laundering Authority (AMLA) is operational and is working on guidelines and technical standards. At the same time, the sixth Anti-Money Laundering Directive is being transposed into national legislation, while the Anti-Money Laundering Regulation (AMLR) will apply directly from 10 July 2027.
The way FIUs operate is also changing. The content and format of reports will be further standardised, information exchange between European FIUs will be expanded, and joint analyses will play a greater role. FIU-Netherlands will also receive additional powers, including the ability to temporarily suspend transactions under certain conditions.
The conclusion of FIU-Netherlands' implementation assessment is clear: the package is feasible, but it requires significant effort from organisations and their operational processes. For obliged entities, much the same applies.
From periodic KYB to an up-to-date customer view
The most important change is not just about new regulations, but about how information is used. Compliance is becoming increasingly dependent on accurate, reliable and standardised data. This creates a challenge for traditional KYB processes, where a file is built during onboarding and the customer is only reviewed again during the next periodic review.
Risks do not follow a calendar. Directors change, ownership structures evolve and sanctions can be expanded in the meantime. The question is therefore shifting from have we investigated this customer properly? to how do we keep the customer profile up to date?
Where perpetual KYB comes in
Perpetual or event-driven KYB aligns with this development. Instead of reviewing a file only at fixed intervals, a relevant event can trigger a new review of the customer.
This could include changes in management, ownership or UBO structure, new sanctions or PEP listings, or signals that do not fit the existing profile. The goal is not to repeat every check more often, but to focus attention on files where something has actually changed.
This makes compliance more targeted and efficient, while helping organisations identify relevant risks more quickly.
Interesting read: Perpetual KYC: why customer due diligence doesn't stop after onboarding
KYB is increasingly becoming a data challenge
Perpetual KYB only works when the foundation is right. Business UBO data and ownership information need to be reliable, remain linked to the correct company and be used consistently across systems.
Towards 2027, the following questions will therefore become increasingly important:
- Is business and UBO data reliable and up to date?
- Is it clear where the information comes from?
- Can systems exchange data effectively?
- Is it defined which changes should trigger a reassessment?
- Can you explain afterwards what a decision was based on?
This foundation determines how easily organisations can support new regulations, further automation and AI.
Interesting read: Why reliable context is crucial for AI in KYB
10 July 2027 is a deadline, not a starting point
The key lesson from the FIU Annual Report is that the transition to the new European AML landscape has already begun. Improving data quality, connecting systems and adapting processes takes time.
10 July 2027 is therefore not a starting point, but a deadline. Organisations that strengthen their KYB foundation now will be better prepared for new regulations while also gaining more control over their current compliance processes.
Want to know where your organisation stands towards 2027? Talk to our compliance experts and discover which steps are most relevant for your KYB process.
