The European Union has made a significant move to reshape its anti-money laundering (AML) framework by creating the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), based in Frankfurt. This new institution is set to standardize and improve AML compliance throughout the EU, eliminating fragmented oversight and establishing a consistent supervisory system.
AMLA Roadshow in Hungary: Building Bridges for Future Supervision
As part of its initial outreach, AMLA organized a roadshow in Hungary in October 2025. AMLA Chair Bruna Szego met with officials from the National Bank of Hungary (MNB), government departments, self-regulatory organizations, and industry stakeholders. The meetings centered on preparing for the forthcoming EU AML legislative package, achieving supervisory alignment, and addressing sector-specific issues. This visit highlighted AMLA’s dedication to open dialogue and joint policy development, setting expectations for its future involvement in both direct and indirect supervision across the EU.
Looking ahead, AMLA will concentrate on preparing for the implementation of the new AML legislation. This includes the development of a wide range of secondary and tertiary legal instruments, as well as the creation of methodologies and tools to support both direct and indirect supervisory roles. Notably, AMLA will begin direct supervision of selected obliged entities starting in 2028, representing a major change in how AML supervision is managed across the EU.
Recent AML Initiatives by the MNB
Meanwhile, the MNB continues to play an active role in monitoring service providers in Hungary to ensure compliance with AML requirements. The newly issued MNB Decree 14/2025 (VI.16.) has tightened rules regarding customer due diligence and beneficial owner verification. For instance, if there is any uncertainty regarding the identity of a beneficial owner, service providers are now required to conduct a customer due diligence interview with the client and, depending on the risk level, with the beneficial owner as well. New compliance obligations have been extended to crypto asset service providers. Additionally, the regulations concerning enhanced due diligence and the creation of internal risk assessments have been updated.
Draft Bill on New Regulatory Instrument
Hungary’s AML landscape is also being shaped by other legislative changes. A recent bill aims to transpose EU Directive 2024/1260 (Directive) on asset recovery and confiscation, introducing a new legal concept: confiscation of assets of unknown origin in the case of certain criminal offenses, such as money laundering. Article 16 of the Directive establishes a framework for extended confiscation, allowing authorities to seize assets that are indirectly linked to criminal organizations – even if not tied to a specific crime. Under this provision, unless proven otherwise, assets acquired within five years prior to the initiation of criminal proceedings may be subject to confiscation if the individual was involved in a criminal organization for financial gain and their property or lifestyle is significantly disproportionate to their lawful income and personal circumstances.
The Directive stipulates that for confiscation to occur, the property must be identified during an investigation, the court must be convinced that the asset originates from criminal activity – specifically from offenses committed within the framework of a criminal organization – and that the asset likely provides substantial economic benefit. Moreover, when deciding on confiscation, the Directive calls for a thorough review of all case-specific details, including available evidence and any links the individual may have to people associated with criminal organizations.
At the time of writing, the draft legislation remains at the proposal stage; however, if enacted, it has the potential to materially strengthen the legal framework for the recovery of assets derived from money laundering activities.
Legal Reforms Aimed at Bolstering Hungary’s AML Framework
The EU is entering a pivotal period in its campaign against financial crime. With the series of legislative developments at both the EU and national levels, the regulatory landscape is evolving rapidly. AMLA’s recent roadshow in Hungary, stricter due diligence requirements introduced by the MNB, and the proposed transposition of the Directive all signal a coordinated push toward more robust and harmonized anti-money laundering enforcement in Hungary.
By Fanny Fabian, Junior Associate, and David Kohegyi, Partner, DLA Piper Hungary
This article was originally published in Issue 12.10 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.
