14/10/2026

What to Ask an AML Consultant Before AMLR 2027

Demand for AMLR help is rising and quality varies. Whether you choose us or someone else, these are the questions I would put to any adviser.

Questions

Which articles will you test me against? A real answer names them: Article 10 for the risk assessment, Article 11 for governance, Articles 19 and 20 for CDD, Articles 51 and 52 for beneficial ownership, Article 77 for records. Read them yourself on EUR-Lex first.
What will you do with my customer files? Good work involves a sample. Be wary of anyone who proposes only a policy review.
How do you handle draft standards? Many AMLA texts were still in consultation in 2026. A good adviser separates what is final from what is expected, and points you to the AMLA site.
Do you know my regulator? In Malta, that means the FIAU and its expectations. Cross-border firms need someone who can read both.
Who does the work? Ask who will actually be on your file, and their experience.
What do I get at the end? A gap report with owners, dates and priorities beats a 90-page document.
What stays with me? You cannot outsource accountability. Under Article 11 of the AMLR, a board member and your compliance officer carry it, and Article 18 says the obliged entity stays fully liable for outsourced tasks and must notify the supervisor before they start.
What does a smaller scope look like? A one-day scoping session, a file sample, or a policy health check should be options.

A fixed price quoted before anyone has asked about your business.
“Fully AMLR compliant” software or packages. Compliance is a state you demonstrate, not a product you buy.
No mention of the transposition law in your country.

Run your own readiness checklist first so the conversation starts from facts, then look at common gaps.

Want to try these on us? The enquiry form is open, and we expect the awkward questions.

General information, not legal advice.