EU CNCL Anti-Money Laundering Rules

Updated on: Mar 21, 2025

Latest Event


  • Mar. 2025 Corrigendum
  • On Mar. 20, 2025, EU CNCL issued corrigendum to Reg 2024/1624 on the prevention of the use of the financial system for purposes of money laundering or terrorist financing.
  • Wording amendments to Swedish (page 61, Article 26(4), second subparagraph), Finnish (page 41, Article 3(3)(b)) and Spanish (page 11, recital 55) language versions.

On Jan. 18, EU CNCL, EP, reached agreement on directive, regulation.

  • Anti-money laundering: the EU Council and Parliament strike deal on stricter rules.
  • Follows EU CNCL May 2023 issued information notes attaching three-column tables on AMLD, AMLR and AMLA proposals showing initial positions before talks, see #167599.
  • Follows EU CNCL Dec. 2023 confirmed that it reached a common understanding with the EP on the process for selecting the seat of future European AMLA, see #194700.
  • New AML Package
  • All rules applying to private sector will be transferred to new regulation, while directive will deal with the organization of AML/CFT systems at national level in member states.
  • The provisional agreement on an anti-money laundering regulation will, for the first time, exhaustively harmonize rules throughout EU, closing possible loopholes used by criminals to launder illicit proceeds or finance terrorist activities via financial system.
  • The agreement on the directive will improve the organization of national AML systems.
  • AMLR - Obliged entities
  • Obliged entities, such as financial institutions, banks, real estate agencies, asset management services, casinos, and merchants play a central role as gatekeepers in AML/CTF framework, as they have a privileged position to detect suspicious activities.
  • The provisional agreement expands the list of obliged entities to new bodies.
  • The new rules will cover most of the crypto sector, forcing all crypto-asset service providers (CASPs) to conduct due diligence on their customers; means that they will have to verify facts and information about customers, and report suspicious activity.
  • According to the agreement, CASPs will need to apply customer due diligence measures when carrying out transactions amounting to €1000 or more.
  • It adds measures to mitigate risks in relation to transactions with self-hosted wallets.
  • Other sectors concerned by due diligence and reporting obligations will be traders of luxury goods such as precious metals and stones, jewelers, horologists, goldsmiths.
  • Traders of luxury cars, airplanes, yachts, cultural goods also become obliged entities.
  • The provisional agreement recognizes that the football sector represents a high risk and expands the list of obliged entities to professional football clubs and agents.
  • However, as the sector and its risk is subject to wide variations, member states will have the flexibility to remove them from the list if they represent a low risk.
  • The rules will apply after a longer transition period, kicking in 5 years after entry into force, as opposed to 3 years for the other obliged entities.
  • AMLR - Enhanced due diligence
  • The Council and Parliament also introduced specific enhanced due diligence measures for cross-border correspondent relationships for crypto-asset service providers.
  • The Council and Parliament agreed that credit and financial institutions will undertake enhanced due diligence measures when business relationships with very wealthy (high net-worth) individuals involve the handling of a large amount of assets.
  • The failure to do so will be considered an aggravating factor in the sanctioning regime.
  • AMLR - Cash Payments
  • EU-wide maximum limit of €10 000 is set for cash payments, making it harder to launder dirty money; MSs will have the flexibility to impose a lower maximum limit.
  • In addition, obliged entities will need to identify and verify the identity of a person who carries out an occasional transaction in cash between €3,000 and €10,000.
  • AMLR - Beneficial Ownership
  • Agreement makes the rules on beneficial ownership more harmonized and transparent.
  • It clarifies that beneficial ownership is based on ownership and control; both need to be analyzed to identify all beneficial owners of legal entity or across types of entities, including non-EU entities when they do business in EU or purchase real estate.
  • Agreement sets the beneficial ownership threshold at 25%; related rules applicable to multi-layered ownership and control structures are also clarified to make sure hiding behind multiple layers of ownership of companies won’t work anymore.
  • In parallel, data protection and record retention provisions are clarified to make the work of the competent authorities easier and faster.
  • The agreement provides for the registration of the beneficial ownership of all foreign entities that own real estate with retroactivity Jan. 1, 2014.
  • AMLR - High-risk Third Countries
  • Obliged entities will be required to apply enhanced due diligence measures to occasional transactions and business relationships involving high-risk third countries whose shortcomings in their national anti-money laundering and counter-terrorism regimes make them represent a threat to the integrity of the EU’s internal market.
  • The Commission will make an assessment of the risk, based on the financial action task force listings (FATF, the international standard setter in anti-money laundering).
  • Furthermore, the high level of risk will justify the application of additional specific EU or national countermeasures, whether at level of obliged entities or by member states.
  • AMLD - Beneficial Ownership Registers
  • Information submitted to central register must be verified; entities or arrangements associated with those subject to targeted financial sanctions will need to be flagged.
  • Directive grants the entities in charge of registers the power to carry out inspections at premises of entities registered, in case of doubts regarding accuracy of information.
  • The agreement also establishes that in addition to supervisory and public authorities and obliged entities, among others, persons of the public with legitimate interest, including press and civil society, may access the registers.
  • To facilitate investigations into criminal real estate schemes, the text ensures that real estate registers are accessible to competent authorities through a single access point.
  • AMLD - Responsibilities of FIUs
  • Each member state has already established financial intelligence unit (FIU) to prevent, report and combat money laundering and terrorist financing.
  • These FIUs are responsible for receiving and analyzing information relevant to money laundering and terrorist financing, notably in the form of reports from obliged entities.
  • According to the agreement, FIUs will have immediate and direct access to financial, administrative and law enforcement information, including tax information, information on funds and other assets frozen pursuant to targeted financial sanctions.
  • Also information on transfers of funds and crypto-transfers, national motor vehicles, aircraft and watercraft registers, customs data, national weapons and arms registers.
  • FIUs continue to disseminate information to NCAs tasked with combatting ML/TF, including authorities with an investigative, prosecutorial or judicial role.
  • In cross border cases, FIUs will cooperate more closely with their counterparts in the member state concerned with the suspicious report; the FIU.net system will be upgraded to enable the fast dissemination of cross-border reports.
  • According to the provisional agreement, applying fundamental rights is confirmed as an integral part of the FIU’s work and taken into account when making decisions.
  • The agreement sets out a firm framework for FIUs to suspend or withhold consent to a transaction, in order to perform its analyses, assess the suspicion and disseminate the results to the relevant authorities to allow for the adoption of appropriate measures.
  • AMLD - Supervisors
  • According to agreement, member states will ensure that obliged entities established in territory are subject to adequate and effective supervision by one or more supervisors.
  • Supervisors will apply a risk-based approach; supervisors will report to the FIUs instances of suspicions; similar to provisions in the AMLA regulation, new supervisory measures for the non-financial sector, so-called supervisory colleges, are introduced.
  • AMLA will develop draft regulatory technical standards defining the general conditions that enable the proper functioning of AML/CFT supervisory colleges.
  • AMLD - Risk Assessment
  • According to agreement, both EU and national risks assessments remain important.
  • EC will conduct an assessment of the risks of money laundering and terrorist financing and draw up recommendations to member states on measures that they should follow.
  • Member states will also carry out risk assessments at national level and commit to effectively mitigating the risks identified in the national risk assessment.
  • Next Steps
  • The texts will now be finalized and presented to member states’ representatives in the Committee of permanent representatives and the European Parliament for approval.
  • If approved, the Council and the Parliament will have to formally adopt the texts before they are published in the EU’s Official Journal and enter into force.
  • Feb. 15, 2024 Final Compromise Texts
  • On Feb. 15, 2024, EU CNCL issued notes attaching final compromise texts on AMLD, AMLR and AMLA proposals; Coreper invited to approve texts of draft regulations and draft directive as set out in documents 6220/24, 6222/24 (with exception of the location of seat in Article 4), and 6223/24 with a view to an agreement at first reading.
  • Also invited to give the Chairman of Coreper mandate to inform chair of EP ECON and LIBE committees that should EP adopt the texts in exact form as set out in documents 6220/24, 6222/24, and 6223/24 the Council would adopt the proposed acts.
  • Feb. 19, 2024 EU CNCL Letter to EP
  • On Feb. 19, 2024, EU CNCL issued information note attaching offer letter to EP ECON.
  • On Feb. 22, 2024, EP, EU CNCL confirmed Frankfurt will be AMLA base, see #202276.
  • In Mar. 2024, EC issued report on Directive 2015/849 implementation, see #204324.
  • Apr. 24, 2024 EP Adopts Rules
  • On Apr. 24, 2024, EP announced adoption of package of laws strengthening the EU's toolkit to fight money-laundering, terrorist financing, AMLD, AMLR, AMLA regulation.
  • The new laws will ensure people with legitimate interest have access to beneficial ownership information, give FIUs more powers to suspend suspicious transactions.
  • Include enhanced due diligence measures, checks on customer's identities, to apply to football clubs/agents from 2029, enhanced vigilance rules on ultra-rich individuals.
  • And establishment of AMLA in Frankfurt to supervise the riskiest financial entities.
  • Legislation must be formally adopted by EU CNCL before publication in Journal.
  • EC DG FISMA updated on package, incl. FAQs on AML and AMLA, article on what will change in practice in EU's financial crime prevention landscape, introduction to article.
  • May 2024 EU CNCL on EP First Reading
  • On May 1, 2024, EU CNCL issued notes of Apr. 30 on outcome of EP first readings on the AMLD, AMLR, AMLA; EP's positions reflects what had been previously agreed.
  • The Council should therefore be in a position to approve the Parliament's positions.
  • Acts would then be adopted in wording which corresponds to Parliament's positions.
  • May 8, 2024 Correction
  • On May 8, 2024, EU CNCL issued an information note with details of a correction to document 9204/24, page 2, first paragraph, in relation to Eva Maria Poptcheva.
  • Document dated May 8, 2024, received from EU CNCL May 10, summarized May 15.
  • May 15, 2024 AMLR, AMLA Final Texts
  • On May 15, 2024, EU CNCL issued final texts of the AMLR (PE-CONS 36/24) and AMLA (PE-CONS 35/24) for adoption.
  • May 21, 2024 AMLD Final Text
  • On May 21, 2024, EU CNCL issued final text of AMLD (PE-CONS 37/24) for adoption.
  • May 21, 2024 Proposed Adoption
  • On May 21, 2024, EU CNCL issued item notes concerning proposed adoption of acts.
  • Coreper asked to confirm agreement and to suggest that the Council approve the EP's positions, as set out in PE-CONS 35/24, PE-CONS 36/24, PE-CONS 37/24 as "A" items.
  • If the Council approves Parliament's positions, the legislative acts will be adopted.
  • May 30, 2024 EU CNCL Adoption
  • On May 30, 2024, EU CNCL adopted the package of new AML rules that will protect EU citizens and EU's financial system against money laundering, financing of terrorism.
  • The new, stricter rules will strengthen EU systems in fight against money laundering, and a new agency based in Frankfurt will supervise the work of the actors involved.
  • This is the final step of the adoption procedure, the texts will now be published in EU Official Journal and enter into force, AML Regulation will apply 3 years after this.
  • Member states will have 2 years to transpose some parts of the AML directive and 3 years for others, the new AMLA agency will start its operations in mid-2025.
  • May 31, 2024 Adopted Texts
  • On May 31, 2024, EU CNCL issued final adopted texts of AMLA, AMLR, and AMLD.
  • Document dated May 31, 2024, received from EU CNCL Jun. 3, summarized on Jun. 6.
  • Jun. 2024 Official Journal
  • On Jun. 19, 2024, EU CNCL issued final AMLA Reg 2024/1620, AMLR Reg 2024/1624 and AMLD6 Dir 2024/1640, of May 31, in the EU Official Journal.
  • AMLA regulation shall enter into force on 7th day following that of its publication in the Official Journal of EU, Jun. 26, 2024; it shall apply from Jul. 1, 2025.
  • However, Articles 1, 4, 49, 53, 54, 55, 57 to 66, 68 to 71, 100, 101 and 107 shall apply from Jun. 26, 2024, and Article 103 shall apply from Dec. 31, 2025.
  • AMLR regulation enters into force on the 20th day following that of its publication in the Official Journal of EU, Jul. 9, 2024; it shall apply from Jul. 10, 2027.
  • Except in relation to obliged entities referred to in Article 3, points (3)(n) and (o), to which it shall apply from Jul. 10, 2029.
  • Directive shall enter into force on the 20th day following OJ publication, Jul. 9, 2024.
  • Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with directive by Jul. 10, 2027, subject to the below.
  • Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with Article 74 by Jul. 10, 2025, with Articles 11, 12, 13 and 15 by Jul. 10, 2026, and with Article 18 by Jul. 10, 2029.
  • Dec. 2024 AMLA Chair
  • On Dec. 18, 2024, EP confirmed that MEPs supported the Italian candidate Bruna Szego’s appointment as Chair of the EU Anti-Money Laundering Authority (AMLA).
  • Ms Szego, who currently leads the anti-money laundering supervision and regulation unit at the Bank of Italy, received 569 votes in favor, 20 against, and 61 abstentions.
  • Based in Frankfurt, new EU AMLA is tasked with coordinating the actions of national financial intelligence units and directly overseeing selected risky financial entities.
  • On Nov. 2024, EU AMLA announced virtual meeting to exchange views, see #238524.
  • Jan. 2025 Official Journal
  • On Jan. 24, 2025, EU CNCL issued Dec 2025/632 appointing Ms Bruna Szego for a term of office of four years from Feb. 16, 2025; decision in force on OJ publication.
  • In Mar. 2025, ACAMS issued EU's new AMLA chief first interview, see #246434.
  • Mar. 2025 Corrigendum
  • On Mar. 20, 2025, EU CNCL issued corrigendum to Reg 2024/1624 on the prevention of the use of the financial system for purposes of money laundering or terrorist financing.
  • Wording amendments to Swedish (page 61, Article 26(4), second subparagraph), Finnish (page 41, Article 3(3)(b)) and Spanish (page 11, recital 55) language versions.
Regulators
EP; EU AMLA; EU CMSN; EU CNCL
Entity Types
B/D; Bank; BS; Corp; Exch; Ins; Inv Co; MSB
Reference
OJ L, Corr 2025/90257, 3/20/2025; OJ C, 1/24/2024; Dec 2025/632, 1/21/2024; PR, P10_TA(2024)0067, 12/18/2024; PR, A10-0032/2024, 2024/0802(NLE), 12/16/2024; OJ L, 6/19/2024; PR, Reg 2024/1620, Reg 2024/1624, Dir 2024/1640, PE-CONS 35/1/24 REV 1, PE-CONS 36/1/24 REV 1, PE-CONS 37/1/24 REV 1, 5/31/2024; PR 468/24, 5/30/2024; PR, 9464/24, 9573/24, 9574/24, 5/21/2024; PE-CONS 37/24, 5/16/2024; PR, PE-CONS 35/24, PE-CONS 36/24, 5/15/2024; PR 9204/24 COR 1, 5/8/2024; PR, 5/1/2024; PR, 9198/24, 9204/24, 9205/24, 4/30/2024; Gd, FAQ QANDA/21/3689, P9_TA(2024)0364, A9-0150/2023, P9_TA(2024)0365, A9-0151/2023, P9_TA(2024)0366, A9-0128/2023, PR 20240419IPR20586, 4/24/2024; PR, 2/19/2024; PR, 6713/24, 2/16/2024; PR, 2/15/2024; PR, 6220/1/24 REV 1, 2/13/2024; PR, 6217/24, 6222/24, 6223/24, 2/12/2024; PR, 1/18/2024; COM/2021/420; COM(2021) 421; COM/2021/423; 2021/0239(COD); 2021/0240(COD); 2021/0250(COD); Reg 2015/847; Reg 1093/2010; Reg 1094/2010; Reg 1095/2010; AMLD Dir 2015/849; Citation: PE-CONS 36/24; PE-CONS 35/24; PE-CONS 37/24; AMLA Reg 2024/1620; AMLR Reg 2024/1624; AMLD6 Dir 2024/1640; Dec 2025/632;
Functions
AML; Anti-Bribery; Compliance; Financial; Legal; Operations; Privacy; Registration/Licensing; Reporting; Risk; Tax; Treasury
Countries
European Union; Cross-Border
Category
State
N/A
Products
Banking; Clearing; Commodities; Corporate; Cryptocurrency; Custody; Deposits; Equity; Fund Mgt; Insurance; Loan; Payments; Wealth Mgt
Rule Type
Final
Regions
EMEA
Rule Date
Jan 18, 2024
Effective Date
Jul 1, 2025
Rule ID
198249
Linked to
Reg. Last Update
Mar 20, 2025
Report Section
EU