Anti-Money Laundering

Overview

The EU anti-money laundering package replaces the patchwork of national rules with a single rulebook and a dedicated EU authority. It consists of three main instruments:

• Regulation (EU) 2024/1624 (AMLR): directly applicable obligations for obliged entities, from 10 July 2027;

• Directive (EU) 2024/1640 (AMLD6): national supervision, financial intelligence units and beneficial-ownership registers, to be transposed mostly by 10 July 2027, with the register provisions due earlier;

• Regulation (EU) 2024/1620: the Anti-Money Laundering Authority (AMLA), based in Frankfurt and operational since 2025, which will directly supervise up to 40 high-risk cross-border credit and financial institutions from 2028.

Regulation (EU) 2023/1113 already requires information on the originator and beneficiary to accompany transfers of funds and crypto-assets.

Who is in scope

Obliged entities include credit and financial institutions, auditors, accountants and tax advisers, notaries and lawyers in certain transactions, estate agents, trust and company service providers, gambling providers and crypto-asset service providers. The AMLR extends the list, for example, to traders in certain high-value goods and, from 2029, to certain professional football clubs and agents.

Key obligations

• business-wide risk assessment: identification and assessment of the money laundering and terrorist financing risks to which the entity is exposed;

• internal policies, procedures and controls: proportionate to the nature and size of the business;

• customer due diligence: identification and verification of customers and beneficial owners, understanding of the purpose of the relationship and ongoing monitoring, with simplified or enhanced measures according to risk;

• politically exposed persons and high-risk third countries: enhanced measures;

• reporting: suspicious transactions must be reported to the financial intelligence unit;

• record keeping and training: documentation retained for the legal period and regular training of staff.

Compliance roles and the cash limit

Under Article 11 of the AMLR, a member of the management body must be responsible for compliance, and the management body must appoint a compliance officer with sufficient hierarchical standing to manage day-to-day compliance, act as contact point for supervisors and report suspicions to the financial intelligence unit. Article 80 introduces an EU-wide limit of EUR 10,000 for cash payments in trade in goods and services, and Member States may keep lower limits.

Until July 2027

National laws transposing the current directives continue to apply, such as Law 83/2017 in Portugal and Law 10/2010 in Spain. Organisations should use the transition period to adapt their risk assessment, procedures and governance to the new rulebook.

How we can help

• Compliance Assessment: readiness assessment against the AMLR;

• Implementation Kits: the risk assessment, due-diligence procedures and internal-control templates;

• Fractional Compliance Officer: AML compliance support on retainer;

• Training & Capacity: mandatory training for staff and management.

Related domains: Anti-Corruption · Third-Party & Supply Chain · Whistleblower Protection · Digital Operational Resilience

Official texts: Regulation (EU) 2024/1624 · Directive (EU) 2024/1640 · Regulation (EU) 2024/1620

General information as of October 2026; it does not constitute legal advice. Confirm the applicable requirements with the competent authorities.