The current EU rules on anti-money laundering and countering the financing of terrorism (AML/CFT) apply to insurance intermediaries where they act with respect to life insurance and other investment-related services and to investment firms. The scope of the revised EU rules, in relation to insurance intermediaries remains the same. Only the intermediaries who are subject to the AML/CFT requirements under the current framework will have to comply with the new AML/CFT requirements. The revised rules have also introduced (new) AML/CFT requirements for some consumer and mortgage credit intermediaries.

(Last updated in June 2025)

BIPAR-Steptoe Handbook on the new AML/CFT framework for insurance, credit, and financial intermediaries

The new EU’s legislative package aimed at strengthening the EU framework on AML/CFT will apply from July 2027.  The revised EU AML/CFT framework will require in-scope insurance, financial and credit intermediaries to take additional actions to maintain effective compliance.

The intermediary sector takes the AML/CFT seriously. BIPAR commissioned the Brussels office of Steptoe LLP to draw up a handbook which aims to help associations of in-scope intermediaries and the intermediaries themselves to navigate the requirements of the new AML/CFT framework.

Responsibility for compliance with all relevant EU and national legislation rests with individual firms and we hope that this handbook will encourage market participants, and national regulators and supervisory authorities, to continue building together a realistic and efficient framework and system of AML/CFT.

This handbook is up to date as per March 2025 and does not yet cover the Level 2 or Level 3 more detailed rules. 

We thank the authors, Guy Soussan, Partner, and Algirdas Semeta, Legal Consultant, for their fruitful work and Isabelle Audigier, BIPAR Legal Director, and Rebekka De Nie, EU Policy Manager, who led BIPAR participation in this work.

(September 2025)