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The EU anti-money laundering package: what changes for obliged entities by July 2027

Dr. Gurgen Petrossian, LL.M. · As of 18.10.2026 · 4 min read

Three stacked off-white sheets of paper with a fine grid; a vertical petrol line runs through all layers
Image: AI-generated

In June 2024, the EU published three legal acts in the Official Journal that reorganise the fight against money laundering and terrorist financing:

  • the Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624), which for the first time lays down the obligations of obliged entities directly and uniformly in all Member States,
  • the sixth Anti-Money Laundering Directive (AMLD6, Directive (EU) 2024/1640), which mainly concerns supervision, financial intelligence units (FIUs) and registers and must be transposed into national law,
  • the AMLA Regulation (Regulation (EU) 2024/1620), which established a new EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism.

For companies, the AMLR is the most relevant act. Much of what is currently contained in the German Money Laundering Act (Geldwäschegesetz, GwG) will in future follow directly from the Regulation.

Timetable

  • AMLA: The Regulation applies from 1 July 2025; certain provisions have applied since 26 June 2024 (Art. 108 of Regulation 2024/1620). The Authority has its seat in Frankfurt am Main (Art. 4).
  • AMLR: It applies from 10 July 2027. For football agents and professional football clubs, which are newly added to the group of obliged entities, it applies from 10 July 2029 (Art. 90 AMLR).
  • AMLD6: The transposition deadline is, in principle, 10 July 2027. By way of derogation, the deadlines are 10 July 2025 (Art. 74), 10 July 2026 for the provisions on access to the registers of beneficial ownership (Arts 11 to 14) and 10 July 2029 for the single access point to real estate information (Art. 18) (Art. 78 AMLD6).
  • Direct supervision by AMLA: The Authority starts the first selection process by 1 July 2027 and completes it within six months (Art. 13(4) of Regulation 2024/1620). Credit and financial institutions with a high residual risk profile are selected; in the first round, as a rule, up to 40 entities or groups (Art. 13(2)). According to the recitals, direct supervision is to begin in 2028.

What is new in substance

From the perspective of obliged entities, the following points are particularly noteworthy:

  1. Wider group of obliged entities: In addition to credit and financial institutions and the familiar professional groups, the AMLR covers, among others, crowdfunding service providers, investment migration operators, traders in high-value goods, non-financial mixed activity holding companies, and football agents and professional football clubs (Art. 3 AMLR).
  2. Cash payment limit: Persons trading in goods or providing services may accept or make cash payments only up to EUR 10,000; Member States may set lower limits (Art. 80 AMLR).
  3. Beneficial ownership: A direct or indirect shareholding of 25 % or more constitutes beneficial ownership through an ownership interest; ownership at every level must be taken into account (Art. 52 AMLR).
  4. Regulatory technical standards: Many details are specified by standards drafted by AMLA and adopted by the Commission. On 1 October 2026, AMLA submitted three final drafts to the Commission: on customer due diligence (Art. 28(1) AMLR), on distinguishing between business relationships and occasional transactions (Art. 19(9)) and on group-wide requirements (Arts 16(4) and 17(3)). They are to apply six months after their entry into force (AMLA, 01.10.20261).

National accompanying legislation

In parallel, there is a government bill for an act “for greater fairness by strengthening the customs administration and combating financial crime” (“für mehr Gerechtigkeit durch die Stärkung der Zollverwaltung und die Bekämpfung der Finanzkriminalität”) (Bundesrat printed paper (Drucksache) 446/26 of 14.08.2026; Bundestag printed paper 21/8282 of 30.09.2026). Among other things, it amends the GwG; the act is essentially to enter into force on 1 January 2027. With regard to the registers of beneficial ownership, it refers to Arts 11 to 15 AMLD6. The Bundesrat delivered its opinion on 25 September 2026 (Bundesrat printed paper 446/26 (Beschluss)). The Bundestag held the first reading of the bill on 9 October 2026 and referred it to the committees; the Finance Committee is in charge (Deutscher Bundestag, 09.10.20262). The act has therefore not yet been adopted.

What obliged entities typically examine

  1. Scope: Will the company fall within the group of obliged entities under Art. 3 AMLR in future, even if it is not subject to the GwG today?
  2. GwG–AMLR comparison: Which internal rules are based on GwG provisions that will be replaced by the Regulation in 2027?
  3. Customer due diligence and beneficial ownership: Do the procedures fit the new thresholds and the forthcoming technical standards?
  4. Group structure: Which requirements will apply group-wide in future, including to subsidiaries in third countries?
  5. Supervision: For financial institutions, could direct supervision by AMLA come into consideration?

Open points

Open points are, in particular, the adoption of the technical standards by the Commission, the conclusion of the German legislative procedure and the list of entities to be directly supervised from 2028.

This post provides a general overview of the legal position and does not replace legal advice on individual cases.

Sources

  1. AMLA, press release “AMLA finalises key standards for the private sector”, 01.10.2026: https://www.amla.europa.eu/press-release-amla-finalises-key-standards-private-sector_en (accessed 18.10.2026) ↩

  2. Deutscher Bundestag, Textarchiv „Stärkung der Zollverwaltung und Bekämpfung der Finanzkriminalität“, 09.10.2026: https://www.bundestag.de/dokumente/textarchiv/2026/kw41-de-finanzkriminalitaet-1217574 (accessed 18.10.2026) ↩

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