AMLR · Reg. 2024/1624
The EU single AML rulebook
"A directly applicable regulation that harmonizes due diligence, beneficial ownership, obliged entities and suspicious transaction reporting across the Union."
AMLR, the EU Anti-Money Laundering Regulation 2024/1624
Comprehensive legal advice on the AMLR (Anti-Money Laundering Regulation): the new European single rulebook on anti-money laundering and counter-terrorist financing, directly applicable in all Member States from July 10, 2027.
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- AMLR cash limit
- €10,000
- AMLD6 Directive
- Directive 2024/1640
- AMLA Regulation
- Regulation 2024/1620
Services
Service catalog for adapting to the AMLR
Six areas of legal support so your firm can move smoothly from Law 10/2010 to the new single EU regime under the AMLR, with a program you can defend before AMLA and SEPBLAC.
Assessment
Gap analysis: Law 10/2010 vs. AMLR
Comparative analysis of your current AML/CFT program against the requirements of Regulation (EU) 2024/1624: policies, controls, compliance structure, documentation and thresholds.
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Gap analysisAMLRAMLD6July 10, 2027
Implementation
Turnkey AMLR program
Design and implementation of the complete AML/CFT program under the AMLR: policies, procedures, internal controls, training, compliance governance and reporting.
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AML manualKYCUBOReporting
UBO
Harmonized beneficial ownership
Identification, verification and recording of the beneficial owner under the new AMLR criteria, connected to the national central register and the European platform.
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UBOCentral register
Audit
AMLR transition audit
External review or independent expert report to validate your adaptation to the AMLR and AMLD6 before SEPBLAC or AMLA inspections.
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Expert reportAudit
New sectors
CASPs, luxury goods, football and more
Advice for the new obliged entities under the AMLR: crypto-asset service providers (MiCA), high-value goods traders and professional football clubs.
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CASPLuxury goodsFootball
Training
Training for the OCI and the board
Training programs for the OCI, the compliance function, senior management and employees on the substantive and operational changes introduced by the AMLR.
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OCIBoard
AML package
The AMLR does not stand alone: the complete package
The AMLR is the centerpiece of the new EU framework, but it operates alongside AMLD6, the Regulation establishing AMLA and the Transfer of Funds Regulation (TFR) on transfers of funds and crypto-assets. Understanding all four components is essential to designing the program properly.
AMLD6 · Dir. 2024/1640
Institutional framework and supervision
"A directive governing central UBO registers, national supervision, FIUs, cooperation between authorities and administrative sanctions, to be transposed by July 10, 2027."
AMLAR · Reg. 2024/1620
AMLA: the new EU authority
"The regulation establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), based in Frankfurt, the direct supervisor of high-risk cross-border entities."
TFR · Reg. 2023/1113
Crypto Travel Rule and transfers
"Regulation on information accompanying transfers of funds and crypto-assets. An essential piece for CASPs, payment institutions and banks."
Consequences
Why does the AMLR change the rules of the game?
The AMLR replaces the directive model with a directly applicable regulation. It narrows national discretion, expands the list of obliged entities, raises sanctions and creates a European supervisor (AMLA) with direct powers over cross-border entities.
Direct application: the AMLR does not require transposition. Law 10/2010 will remain relevant for matters not covered by the Regulation, but the core obligations will apply directly.
New obliged entities: the AMLR expressly extends the list to CASPs, credit intermediaries, high-value goods traders and professional football clubs in certain transactions.
Dual supervision: AMLA directly supervises a limited group of high-risk cross-border entities; the rest remain under the national supervisor (SEPBLAC), but in coordination with AMLA.
AMLD6
up to €10,000,000
Maximum pecuniary sanctions raised to €10 million or 10% of total annual turnover for serious, repeated or systematic breaches.
AMLR Art. 80
€10,000
Harmonized limit on cash payments in large transactions, replacing varying national thresholds and strengthening traceability.
Timeline
July 10, 2027
Date of application of the AMLR and transposition deadline for AMLD6. Obliged entities should start adapting their programs now.
Is your firm ready for the AMLR?
July 10, 2027 is closer than it seems. We design a realistic plan to adapt to Regulation (EU) 2024/1624, with clear priorities, milestones and auditable deliverables.
Frequently asked questions
AMLR: common questions
What is the AMLR and when does it apply?
The AMLR (Anti-Money Laundering Regulation) is Regulation (EU) 2024/1624 of May 31, 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing. It was published in the Official Journal of the EU on June 19, 2024.
The AMLR is directly applicable in all Member States from July 10, 2027, without the need for transposition. It largely replaces Directive (EU) 2015/849 (AMLD4) as regards the obligations of obliged entities.
What is the difference between the AMLR, AMLD6 and AMLA?
The EU AML package has three main pieces: the AMLR (Reg. 2024/1624), which sets out the substantive obligations for obliged entities; AMLD6 (Dir. 2024/1640), which governs central registers, supervision, FIUs and administrative sanctions; and the AMLAR (Reg. 2024/1620), which establishes AMLA, the new EU authority based in Frankfurt.
On top of all this comes the Transfer of Funds Regulation (EU) 2023/1113 (TFR) on information accompanying transfers of funds and crypto-assets.
Who are the new obliged entities?
The AMLR extends the list of obliged entities compared with AMLD4. It includes, among others, crypto-asset service providers (CASPs) as defined in the MiCA Regulation, mortgage and consumer credit intermediaries that are not financial institutions, traders in certain high-value goods and, in a move that has drawn wide media attention, professional football clubs when they carry out certain transactions.
Member States may introduce limited exemptions for certain gambling service providers, certain professional football clubs and certain low-risk financial activities.
What changes for CASPs?
The AMLR expressly includes CASPs among obliged entities at EU level. This consolidates the regulation already under way with MiCA and the TFR (Travel Rule), creating a single framework: MiCA license + AMLR obligations + Travel Rule + coordinated supervision.
In practice, CASPs will have to meet the same KYC, monitoring, reporting and UBO obligations as credit institutions, under harmonized criteria.
What does the €10,000 cash limit mean?
The AMLR introduces a harmonized €10,000 limit on cash payments in large transactions, replacing varying national thresholds. The aim is to reduce opportunities for money laundering and strengthen the traceability of higher-value transactions.
Member States may keep stricter limits. In Spain, it has to be coordinated with Law 7/2012 (the cash payment limit currently in force).
How does the UBO regime change?
The AMLR harmonizes beneficial ownership transparency requirements for obliged entities, and AMLD6 details how national central registers must work: they must hold more detailed information (including on third-country entities and legal arrangements) and be interconnected through the European Central Platform.
Access to these registers is open to competent authorities, AMLA and persons with a demonstrable legitimate interest, such as journalists or NGOs.
How does the AMLR affect Spain's Law 10/2010?
Law 10/2010 will remain relevant, but it will have to coexist with the AMLR. Provisions of Law 10/2010 that overlap with the AMLR will be displaced by the direct application of the Regulation. Those that implement aspects of AMLD6 will have to be adjusted through transposition.
This requires a full review of the AML/CFT program: manuals, forms, policies, procedures, training and technology tools.
What role will AMLA play alongside SEPBLAC?
AMLA is the new EU AML/CFT authority based in Frankfurt. It will be responsible for overall coordination, issuing guidelines and technical standards and, above all, direct supervision of a limited number of high-risk cross-border obliged entities.
SEPBLAC will remain the national supervisor for most Spanish obliged entities, in close cooperation with AMLA and within the common framework set by the AMLR.
Operational guide
Practical guide to adapting to the AMLR
The AMLR is not a mere update: it is a paradigm shift. It moves from the "directive + transposition + national criteria" model to "regulation + direct application + European supervisor". Adapting takes time, method and a proper project.
Applicable legislation
Regulation (EU) 2024/1624 (AMLR), Directive (EU) 2024/1640 (AMLD6), Regulation (EU) 2024/1620 (AMLAR), Regulation (EU) 2023/1113 (TFR), Law 10/2010 (on a transitional basis), Law 7/2012, Commission Delegated Regulation (EU) 2016/1675 and the FATF Recommendations.
Key milestones
The AMLR applies from July 10, 2027. AMLA must approve several technical standards by July 10, 2026. AMLD6 must be transposed by then. Internal preparation cannot wait.
What makes the difference
An adaptation project led by the OCI, with clear metrics and auditable deliverables. The supervisor will want to see evidence that the firm has spent years preparing, not that it improvised three weeks before.
AMLR adaptation checklist in 10 steps
- Appoint the project sponsor (OCI) and set up the AMLR adaptation committee with compliance, legal, IT and the business areas affected.
- Carry out a thorough gap analysis of Law 10/2010 vs. AMLR + AMLD6 + AMLAR + TFR, identifying new, amended and unchanged obligations.
- Rewrite AML/CFT policies and procedures to align them with the language and requirements of the AMLR (EU-wide uniformity, no national leeway).
- Review and update the system for identifying, verifying and recording the beneficial owner, connected to the national central register and the European platform.
- Recalibrate the KYC engine, EDD, screening (sanctions, PEPs, FATF list), monitoring and thresholds in line with the new harmonized criteria.
- Adapt the suspicious transaction reporting workflow (DMO/STR) to the uniform EU format that AMLA will develop.
- Map new obliged entities within the group (CASPs, luxury goods, football, etc.) and design specific programs for each category.
- Implement controls on the cash payment limit (€10,000) and the new transparency and reporting obligations.
- Specific AMLR/AMLD6 training plan for the OCI, the compliance function, senior management and employees according to their roles.
- Internal audit and, ideally, an independent external expert report to validate the maturity of the program before July 10, 2027.
The AMLR also reshapes related areas: it strengthens the integration of the FATF list into the risk engine, aligns the obligations of MiCA EMT issuers and CASPs, sets the compliance floor that entities such as SGIICs or firms in the financial sandbox must respect, and raises the bar for independent directors at investment firms (ESIs) in their internal oversight role.
AMLR as a project
From Regulation to program: how to put the AMLR into practice at your firm
The AMLR only makes sense as a multidisciplinary project: legal interprets the rules, compliance turns them into policies, IT builds them into the KYC and monitoring engine, and the business adapts its workflows. Here is the operational dashboard we go through with each client.
1) Gap analysisBaseline assessment
A thorough comparison between the current program under Law 10/2010 and the requirements of the AMLR + AMLD6, identifying gaps, over-compliance and gray areas.
- New obligations
- Amended obligations
- Operational gaps
2) PoliciesAMLR manual and procedures
Rewriting the AML/CFT manual and key procedures (KYC, EDD, monitoring, STRs, training) under the logic of Regulation (EU) 2024/1624.
- AML/CFT manual
- KYC procedures
- Training plan
3) TechnologyKYC and monitoring engine
Technical recalibration of the detection engine: rules, thresholds, lists (FATF, EU, sanctions), customer profiling and audit logs compliant with AMLA standards.
- Dynamic rules
- Integrated lists
- Audit trail
4) UBOBeneficial ownership under the AMLR
The way the UBO is identified, verified and recorded changes. The firm must consult and cross-check against the national central register, connect with the European Central Platform and document discrepancies.
Tip: the AMLR also covers beneficial owners of foreign entities operating in the EU; the documentary trail becomes critical.
Quick decisionPractical map: what should I prioritize for my type of firm?
Banks / EMIs
Full recalibration, with a focus on UBO, cross-border monitoring and possible direct supervision by AMLA.
CASPs
Complete AML program, Travel Rule, MiCA integration and specific training.
New sectors
Designing the program from scratch: luxury goods, football, credit intermediaries and other sectors coming into scope for the first time.
AMLR playbook
Substantive changes in the AMLR compared with AMLD4 / Law 10/2010
Nature
Directive transposed nationally, with criteria varying between Member States.
Directly applicable regulation, with uniform criteria across the EU.
Obliged entities
Closed list inherited from AMLD4, with national interpretations.
Expanded list: CASPs, credit intermediaries, luxury goods, professional football.
UBO
Identification under national criteria, partially interconnected registers.
Harmonized criteria, detailed central registers, interconnected European platform.
Cash payments
Varying national thresholds (in Spain, Law 7/2012).
Harmonized EU limit of €10,000, without prejudice to stricter national limits.
Sanctions
AMLD4 caps: €5 million or 5% of turnover.
AMLD6 caps: €10 million or 10% of turnover. Periodic penalty payments.
Supervision
National supervisors (SEPBLAC) with limited coordination through the EBA.
SEPBLAC + AMLA, with direct supervision of high-risk cross-border entities.
Warning signs of poor AMLR readiness
Typical indicators in AML/CFT programs that will reach July 10, 2027 with problems unless action is taken.
- AML/CFT manual with no gap analysis against the AMLR and no adaptation plan with milestones and owners.
- UBO system based on self-declarations, without systematic cross-checking against official registers.
- Monitoring engine with static rules and no documented rationale for the risk-based approach.
- No specific program for the new obliged entities (CASPs, luxury goods, football) within the group.
- Generic AML/CFT training, not adapted to the AMLR/AMLD6 changes or segmented by role.
Operational glossary
Key concepts for understanding the AMLR
If you work in AML/CFT compliance and your firm has to move from Law 10/2010 to the AMLR, these are the terms that will appear in every manual, every inspection and every report your firm produces from now on.
AMLRReg. 2024/1624
Anti-Money Laundering Regulation
EU regulation on the prevention of money laundering and terrorist financing, directly applicable from July 10, 2027.
Centerpiece of the AML package.
AMLD6Dir. 2024/1640
Sixth AML Directive
Directive governing central UBO registers, national supervision, FIUs, cooperation between authorities and the sanctions regime.
To be transposed by July 10, 2027.
AMLARReg. 2024/1620
AML Authority Regulation
Regulation establishing AMLA, the new EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism, based in Frankfurt and with direct supervisory powers.
Phased start of operations.
AMLAFrankfurt
EU AML Authority
EU AML/CFT supervisor with powers of coordination, technical standards and direct supervision of high-risk cross-border entities.
Cooperates with SEPBLAC and other FIUs.
TFRReg. 2023/1113
Transfer of Funds Regulation
Regulation on information accompanying transfers of funds and crypto-assets. An essential piece for CASPs and payment institutions.
Crypto Travel Rule.
Single rulebookEU
Single AML rulebook
The concept that defines the AMLR: a single, directly applicable body of rules, without national fragmentation, for obliged entities across the EU.
Reduces regulatory arbitrage.
Obliged entitiesExpanded
In Spanish: sujetos obligados
List expanded by the AMLR: banks, EMIs, insurers, advisers, lawyers, CASPs, luxury goods, professional football and credit intermediaries.
Harmonized regime.
UBOBeneficial owner
Ultimate Beneficial Owner
The natural person who ultimately owns or controls a legal entity. The AMLR standardizes the criteria and AMLD6 details the central registers.
Interconnected European platform.
Cash limit€10,000
Harmonized cash limit
The AMLR sets a common €10,000 ceiling on cash payments in large transactions, without prejudice to stricter national limits.
Traceability.
Contact
Book a call
Tell us where your AML/CFT program stands today and we will design a realistic AMLR adaptation plan with clear priorities and auditable deliverables.
AMLR legal framework: Regulation (EU) 2024/1624 and the architecture of the EU AML package
The AMLR (Anti-Money Laundering Regulation) is Regulation (EU) 2024/1624 of the European Parliament and of the Council of May 31, 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing. It was published in the Official Journal of the EU on June 19, 2024 and is the centerpiece of the new EU single rulebook on AML/CFT.
Why the AMLR was adopted: from a directive model to a regulation model
For three decades, AML/CFT obligations were channeled through directives (AMLD1 to AMLD5), transposed with diverging criteria in each Member State. The result was a fragmented internal market, with different national interpretations that made it harder for obliged entities with a European presence to operate and opened the door to regulatory arbitrage. The AMLR tackles this problem by turning the substantive obligations into rules directly applicable in all Member States.
Architecture of the AML package
The AMLR does not apply on its own. It is part of a broader legislative package: Directive (EU) 2024/1640 (AMLD6), which governs the institutional aspects (central registers, national supervisors, FIUs, cooperation, sanctions), and Regulation (EU) 2024/1620 (AMLAR), which establishes AMLA, the new EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism. It is complemented by Regulation (EU) 2023/1113 (TFR) on information accompanying transfers of funds and crypto-assets.
Timing: July 10, 2027
The AMLR is directly applicable from July 10, 2027. AMLD6 must be transposed into national law by the same date (with some exceptions). AMLA must approve several regulatory and implementing technical standards before July 10, 2026. This means obliged entities need to start their internal adaptation project now.
Personal scope: new obliged entities
The AMLR expands the list of obliged entities compared with AMLD4. It expressly includes, among others, crypto-asset service providers (CASPs) as defined in the MiCA Regulation, mortgage and consumer credit intermediaries that are not financial institutions, certain high-value goods traders and professional football clubs in certain transactions, with the possibility of limited national exemptions.
Core obligations for obliged entities
The AMLR consolidates and harmonizes the core obligations: internal policies, procedures and controls to manage risk, customer due diligence, identification and verification of the beneficial owner, and suspicious transaction reporting to the financial intelligence unit. Obliged entities are the gatekeepers of the system and get uniform criteria across the EU.
Cash limit and new measures
One of the most visible changes is the harmonized €10,000 limit on cash payments in large transactions, which replaces varying national thresholds. Member States may keep stricter limits. In Spain, it will have to be coordinated with Law 7/2012, which remains in force to the extent it is not displaced by the AMLR.
Tougher sanctions
AMLD6 expands the sanctions regime inherited from AMLD4. The pecuniary caps for serious, repeated or systematic breaches rise to €10 million or 10% of total annual turnover. It also introduces harmonized minimum administrative measures and the possibility of imposing periodic penalty payments.
Coexistence with Spain's Law 10/2010
Law 10/2010 will remain relevant for matters not covered by the AMLR (areas subject to transposition, detailed technical matters), but obligations that overlap with the Regulation will be displaced by its direct application. A full review of the Spanish AML/CFT program is unavoidable.
AML/CFT services
Related areas
Resources and blog
Official sources
Key legislation, linked to the official text:
- Law 10/2010 of April 28 on the prevention of money laundering and terrorist financingBOE · consolidated text
- Regulation (EU) 2024/1624 of May 31, 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financingEUR-Lex · Official Journal of the EU
- Law 7/2012 of October 29 amending tax and budget legislation and adapting financial legislation to step up action to prevent and combat fraudBOE · consolidated text
Legislation and links reviewed in .