The New EU AML Package

The European Commission’s latest AML package addresses urgent vulnerabilities in the area of combating money laundering and terrorist financing (AML/CFT). Its purpose is to strengthen EU-wide AML/CFT rules and harmonise requirements across member states, closing existing legal gaps.

The package includes:

• The regulation establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) (AMLAR-Regulation (EU) 2024/1620)
• The regulation on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLR-Regulation (EU) 2024/1624)
• The directive on the mechanisms to be put in place by Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (6^th AML-Directive)
• The regulation that recasts the regulation on the transmission of information accompanying transfers of funds and certain crypto assets (ToFR, Regulation (EU) 2023/1113, in effect since 29 June 2023; applies since 30 December 2024)

In May 2024, the AML package was formally adopted and published in the Official Journal of the EU on 19 June 2024. After entering into force on 9 July 2024, the AML Regulation will apply directly from 10 July 2027. The Member states must transpose the directive by the same date. Deviating implementation deadlines apply for the access to transparency registers (by 10 July 2025) and the establishment of real‑estate registers (by 10 July 2029).

The AML-package introduces significant changes for companies and financial institutions.

Establishment of the EU AML Authority (AMLAR)

At the core of the reform is the establishment of the AMLA as a new European authority to combat money laundering, headquartered in Frankfurt. Following the appointment of its Executive Board in May 2025 and the establishment of its structures, AMLA is now operational. Starting from January 1, 2028, it will directly supervise 40 large, high‑risk financial institutions EU‑wide and support national authorities in combating money laundering and terrorist financing. AMLA will facilitate joint analysis of cross‑border cases by national Financial Intelligence Units (FIUs) and provide analytical and information‑sharing solutions. It will serve as a central coordination point to ensure unified standards across the EU and the efficient handling of cross‑border cases.

EU‑wide AML Regulation (AMLR)

A milestone of the package is the introduction of an EU‑wide AML Regulation. Effective from July 1, 2027, it will replace the previous AML Directive and establish a single rulebook. The goal is to harmonise national provisions and close regulatory gaps.

1. Stricter due diligence obligations

The AML package significantly tightens due‑diligence requirements. Companies and financial institutions must more precisely identify and continuously monitor the beneficial owners of their business partners. Suspicious‑activity reports must be submitted more promptly and reliably, with the AMLR imposing a five‑working‑day deadline for responding to FIU requests.

Enhanced due diligence also applies to crypto‑asset service providers.

2. Cash Payment Cap

A Europe-wide upper limit of 10,000 euros for cash payments in the business sector will be introduced. EU‑wide payments above 10,000 euros are prohibited in cash. Member states may impose lower limits. In addition, obliged entities will be required to verify and identify their customers for cash payments of 3.000 Euro or more. This measure aims to enhance transaction traceability and discourage the illicit use of cash.

3. Expansion of the Obliged Entities

The AMLR broadens the list of obliged entities to include crypto‑asset providers, crowdfunding platforms and intermediaries, professional football clubs and agents, traders of high‑value goods such as precious metals and gemstones, and other high‑value goods dealers. The national authorities may grant an exemption from the obligation for actors with a low money laundering risk. Meanwhile, ordinary goods traders will no longer be included, though they remain subject to general criminal liability under Sect. 261 of the German Criminal Code (StGB).

4. Beneficial‑Ownership Threshold

The definition and thresholds for beneficial ownership have been standardised EU‑wide. A beneficial owner is anyone with at least 25 % ownership, voting rights, or other ownership interests in a company — exceeding the 25 % threshold will no longer be required. For high‑risk sectors, the European Commission may lower the threshold to 15 %. These harmonised standards aim to prevent the misuse of complex corporate structures to obscure ownership.

Extension and Harmonisation of Transparency Registers (6th AMLD)

The directive requires the requires the responsible authorities to continuously verify the accuracy of the information on beneficial owners in the registers. Member States must also establish a real estate register. To improve the traceability of corporate structures, the directive mandates the interconnection of national transparency registers and the creation of centralised European access point. These measures aim to facilitate access to information about beneficial owners in complex networks and enhance transparency for national authorities and institutions.

Key Provisions of the New Transfer of Funds Regulation (ToFR)

The revised version of the Money Transfers Regulation is intended to tighten transparency requirements for crypto transfers and strengthen the traceability of transactions. The Money Transfers Regulation implements the so-called FATF standards (Travel Rule) to ensure complete traceability of money flows.

Conclusion: Unity and Transparency

The AML package sets important milestones in the combating of money laundering and terrorist financing. The introduction of unified standards, the establishment of the new supervisory authority (AMLA), and consistent obligations for obliged entities represent meaningful steps in the evolution of AML/CFT frameworks. For companies and financial institutions, it is now crucial to pay attention to the implementation deadlines and to prepare early for the new requirements. These harmonised measures promise high level of transparency and may reinforce the integrity of the European internal market.

Authors: Nadine Forstmann, Pelin Sentürk und Macide Sarican