New EU AML package

In January 2024, the European Union took a decisive step in the fight against money laundering: agreement was reached on the EU-wide anti-money laundering (AML) package. This package represents a change in the regulatory architecture of money laundering compliance in Europe and is a response to the previous challenges and inconsistencies in the regulations in the member states.

Need for change

Until now, the regulations at European level were based on EU money laundering directives, which then had to be transposed into national law in the individual member states. These processes often took a long time and sometimes led to considerable differences between countries in the implementation of the directive's regulations. In addition to a 6th EU Money Laundering Directive, the new AML package introduces an EU Money Laundering Regulation, which covers key areas of regulation. As a regulation, it is directly applicable in the member states in the same way.

Key points of the new AML package

The new AML package provides for many areas of regulation. We have summarised some important areas of regulation:

Cash payment limit

An important component of the package is the setting of an EU-wide upper limit for cash payments at 10,000 euros. However, the member states have the option of lowering this limit further. In some countries, significantly lower upper limits have already been set.

Expansion of the group of obligated parties

The package significantly expands the group of obligated parties. The new regulations will oblige the majority of providers of crypto services to implement due diligence obligations in relation to their customers. Among other things, they will have to subject customers to a know-your-customer (KYC) check for transactions of 1,000 euros or more. Professional football clubs and agents will also be obliged to comply with the regulation in future. However, member states can exempt professional football clubs in their country from the regulation under certain conditions.

Increased due diligence and transparency

In future, credit and financial institutions will have to apply increased due diligence obligations when managing the large assets of very wealthy individuals. In addition, transparency will be increased through detailed regulations on beneficial ownership and the obligation to register in transparency registers for foreign companies that own real estate.

Introduction of an EU supervisory authority

A central component of the package is the establishment of the Anti-Money Laundering Authority (AMLA), an EU-wide supervisory authority that will ensure the uniform application of the rules. It will also directly supervise some obliged entities (e.g. certain large credit institutions).

Next steps

The final texts still have to be formally adopted and approved. The vote in the European Parliament is scheduled for the end of April, after which it will be published in the Official Journal of the European Union. The EU regulation is therefore expected to apply from mid-2027.

You can find out more on the Page of the European Parliament.