EU Anti-Money Laundering
AML PACKAGE: AMLR + AMLD6 + AMLA
The EU's comprehensive overhaul of its anti-money laundering framework. Three interconnected instruments -- a directly applicable regulation (AMLR), a directive (AMLD6), and a new supranational authority (AMLA in Frankfurt) -- replace the fragmented directive-based approach with a single rulebook, centralised supervision, and harmonised enforcement across all 27 Member States.
Money laundering is the process of making illegally obtained money appear legitimate. Terrorist financing is the channelling of funds -- legal or illegal -- to support terrorism. Both rely on the same infrastructure: banks, shell companies, property deals, crypto wallets, and professional intermediaries willing to look the other way. The EU's anti-money laundering framework exists to shut down those channels.
Until 2024, the EU relied on directives -- rules that each Member State had to translate into its own national law. The result was 27 slightly different rulebooks, creating gaps that criminals could exploit by routing transactions through countries with weaker controls. The 2024 AML Package fixes this. Its centrepiece, the Anti-Money Laundering Regulation (AMLR), is a single rulebook that applies identically across every EU country from July 2027. Alongside it, a new EU agency -- AMLA, based in Frankfurt -- will directly supervise the riskiest cross-border financial institutions and coordinate national enforcement.
In practical terms, if your business is on the "obliged entity" list -- banks, payment firms, crypto exchanges, estate agents, accountants, even professional football clubs -- you must know who your customers really are, understand where their money comes from, and report anything suspicious. There is now a hard EU-wide limit of EUR 10,000 on cash payments for commercial transactions. Countries that already enforce stricter limits, like France at EUR 1,000, keep those in place.
The penalties for failure are substantial: fines up to EUR 10 million or 10% of annual turnover, plus personal liability for senior management. More importantly, AMLA can now step in when national regulators fail to act -- ending the era of enforcement gaps that allowed some of Europe's largest money laundering scandals to unfold.
The 2024 AML Package consists of three interconnected legal instruments that together create the EU's new anti-money laundering architecture.
The Anti-Money Laundering Authority in Frankfurt represents a structural shift in EU AML enforcement -- from national-only supervision to centralised oversight.
Legal establishment, recruitment of Executive Director and staff, setting up Frankfurt headquarters.
AMLA becomes operational with initial staff. Begins indirect supervisory role, FIU coordination, and RTS drafting.
First selection of directly supervised entities based on cross-border risk criteria and inherent risk profiles.
Development of binding regulatory technical standards, implementing technical standards, and supervisory guidelines under AMLR.
AMLA begins direct supervision of selected highest-risk cross-border financial entities with on-site inspections.
Full supervisory, enforcement, and coordination powers operational. Periodic review of supervised entity population.
The AMLR significantly expands the list of obliged entities. Professional football clubs, investment migration operators, and crypto-asset service providers are now explicitly included.
The AMLR harmonises CDD requirements across all Member States. Every obliged entity must follow this process for each business relationship.
The AMLR maintains the risk-based approach as the cornerstone of AML compliance. Obliged entities must assess these risk dimensions to determine the appropriate level of due diligence.
The AMLR introduces a harmonised EUR 10,000 ceiling, but many Member States already enforce stricter national limits. The AMLR sets a maximum, not a minimum.
| JURISDICTION | LIMIT (EUR) | STATUS | NOTE |
|---|---|---|---|
| EU-wide (AMLR) | 10,000 | From July 2027 | Harmonised limit under AMLR. Member States may maintain lower national limits. |
| France | 1,000 | In force | EUR 1,000 for residents, EUR 15,000 for non-residents |
| Italy | 5,000 | In force | Raised to EUR 5,000 in January 2023 (previously EUR 1,000 from 2022; increased under Meloni government) |
| Spain | 1,000 | In force | EUR 1,000 for residents, EUR 10,000 for non-residents |
| Belgium | 3,000 | In force | EUR 3,000 for consumer goods transactions |
| Germany | None | ID from 10,000 | No cash limit, but identity verification required above EUR 10,000 |
| Netherlands | None | AMLR will apply | Currently no limit; EUR 10,000 harmonised limit will apply from 2027 |