EU Anti-Money Laundering Regulation starts to apply

The Anti-Money Laundering Regulation (AMLR) is the EU single rulebook against money laundering and terrorist financing. It sets how banks and other obliged entities, the businesses the law covers, identify their customers, find out who really owns them and report suspicions (Regulation (EU) 2024/1624 (external site)).

Because it is a regulation and not a directive, the same text applies directly in every Member State from 10 July 2027. It replaces the fourth Anti-Money Laundering Directive (EUR-Lex summary (external site)).

Until 10 July 2027, the obligations come from national laws that transposed Directive (EU) 2015/849 (external site), so details differ from country to country. From that date, the core obligations sit in one directly applicable text.

Customer due diligence (CDD), the checks on who a customer is and what the relationship is for, applies when a relationship starts, for occasional transactions of EUR 10,000 or more, and whenever money laundering is suspected (EUR-Lex summary (external site)). The checks cover the identity of the customer and of its beneficial owners, the natural persons who ultimately own or control it.

Due diligence also includes checking whether the customer or its beneficial owners are subject to targeted financial sanctions, such as asset freezes (Regulation (EU) 2024/1624 (external site)).

Suspicions go to the Financial Intelligence Unit (FIU), the national body that receives and analyses such reports, and records are kept for five years. Credit institutions, financial institutions and crypto-asset service providers may not keep anonymous accounts (EUR-Lex summary (external site)).

As an example, a customer who opens accounts in two Member States meets the same core identification rules in both, because the rule is one text (Regulation (EU) 2024/1624 (external site)).

Obliged entities include credit institutions and financial institutions such as investment firms, asset managers, payment institutions, insurers, crypto-asset service providers and fund administrators (EUR-Lex summary (external site)). The roles most directly concerned:

• KYC Analyst: identification and verification steps follow the articles of the regulation instead of national law.
• Corporate Onboarding Analyst (KYC): beneficial ownership checks on companies and trusts follow the common EU rules.
• Periodic Review Analyst (KYC): ongoing reviews of existing customers apply the same common standard.
• AML Analyst: suspicion reports to the FIU follow the regulation's reporting duty.
• Sanctions Analyst: checks on targeted financial sanctions become part of customer due diligence.
• Financial Crime Investigations Associate: investigation files support reports to the FIU under one EU rule.
• Compliance Officer: internal policies and controls are measured against a single text.
• Regulatory Change Analyst: national rules are compared with the regulation and the differences listed.

The regulation was published in the Official Journal on 19 June 2024 and entered into force in July 2024 (Regulation (EU) 2024/1624 (external site)).

It applies from 10 July 2027, a confirmed date. For professional football clubs and football agents, it applies from 10 July 2029 (EUR-Lex summary (external site)).

EU anti-money laundering rules began as directives, which each Member State transposes into its own law. The fourth directive of 2015, Directive (EU) 2015/849 (external site), was the last of that kind for obliged entities.

The 2024 package splits the subject in three. The AMLR holds the rules for obliged entities, Directive (EU) 2024/1640 (external site) covers national supervisors and FIUs, and Regulation (EU) 2024/1620 (external site) creates the Anti-Money Laundering Authority (AMLA).