Regulation (EU) 2024/1624: The End of Europe’s Anti-Money Laundering Patchwork

From 27 national laws to a single rulebook

For years, an entity operating in several EU countries has had to comply with different versions of the same obligations, one for each Member State. That will end on 10 July 2027. From that date, anti-money laundering and counter-terrorist financing (AML/CFT) will no longer depend on 27 national laws: Regulation (EU) 2024/1624, known as the AMLR or the “single rulebook”, will apply directly to all obliged entities across the Union, without the need for national transposition.

The AMLR is part of the European AML/CFT package adopted on 31 May 2024, together with:

• Regulation (EU) 2024/1620, which establishes the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), based in Frankfurt. From 2028, AMLA will directly supervise a limited group of high-risk, cross-border financial entities.
• Directive (EU) 2024/1640 (the sixth directive, or AMLD6), which governs matters that remain national: supervisors, financial intelligence units (FIUs), beneficial ownership registers and the sanctions regime. Its general transposition deadline is also 10 July 2027, with some milestones staggered across 2025 and 2029.

Once the AMLR applies, Directive (EU) 2015/849 (AMLD4), as amended by Directive (EU) 2018/843 (AMLD5), will be repealed. Those directives have served as the reference framework for the past decade.

From a minimum-harmonisation directive to a maximum-harmonisation regulation

The most important change is not a specific obligation, but the type of legal instrument. This may seem technical, but it changes everything. AMLD4 and AMLD5 were minimum-harmonisation directives: they set a baseline and allowed each Member State to impose stricter rules. The result was a patchwork of different requirements and delayed transposition.

The AMLR reverses that logic. Its obligations for obliged entities—customer due diligence, internal controls, beneficial ownership, reporting of transactions and record-keeping—will be the same throughout the Union. Member States will retain discretion only where the Regulation expressly allows it, for example:

• Extending the scope of obliged entities to sectors presenting specific national risks (Article 4), subject to notification to the Commission.
• Maintaining or setting cash-payment limits below €10,000 (Article 80), following consultation with the European Central Bank.
• Organising supervision, FIUs, beneficial ownership registers and sanctions, which are matters governed by AMLD6.

The practical consequences are twofold. For obliged entities, regulatory arbitrage between countries will disappear. For national legislators, the task will no longer be to transpose the rules, but to clean up the statute book: repealing provisions that contradict or duplicate the Regulation and retaining only those permitted by the AMLR and AMLD6.

What changes compared with AMLD4/AMLD5

The AMLR tightens thresholds, expands the scope of obliged entities and turns into common rules matters that were previously left to national discretion. The following changes are likely to have the greatest day-to-day impact on obliged entities:

Area	Directive 2015/849 (AMLD4/AMLD5)	Regulation 2024/1624 (AMLR)
Nature	Minimum-harmonisation directive; requires transposition.	Directly applicable from 10 July 2027.
Occasional transactions	Customer due diligence required from €15,000.	From €10,000; identification required for cash transactions from €3,000 (Article 19).
Cash-payment limit	No EU-wide limit; traders receiving €10,000 or more in cash were obliged entities.	Common €10,000 limit for cash payments to traders supplying goods and services; Member States may retain lower limits (Article 80).
Beneficial owner	Indicator: holding “more than 25%”.	“25% or more” (Article 52), with detailed rules on control by other means and multi-layered structures.
Politically exposed persons (PEPs)	Open-ended list; Member States applied their own criteria to local officeholders.	Harmonised list, including heads of regional and local authorities in areas with 50,000 inhabitants or more (Article 2); enhanced measures for at least 12 months after leaving office (Article 45).
High-net-worth clients	No specific regime.	Enhanced due diligence for clients with assets of at least €50 million (Article 34).
Customer due diligence updates	Periodic, based on risk, with no fixed deadline.	Maximum intervals: annually for high-risk clients and every five years for others (Article 26).
Obliged entities	Includes providers of cryptocurrency exchange and custody services and art-market participants (AMLD5).	Adds all crypto-asset service providers under MiCA, crowdfunding platforms, investment migration operators, traders in high-value goods, and professional football clubs and agents (the latter from 2029).
Anonymity	Anonymous accounts and passbooks prohibited.	Ban extended to anonymous crypto-asset accounts; existing bearer shares must be converted or immobilised before 10 July 2029 (Article 79).
Internal organisation	Referred to national law.	Compliance manager at management-body level, operational compliance manager and independent audit function (Articles 9 and 11).
Supervision	Exclusively national.	National supervision coordinated by AMLA, which will directly supervise selected entities.

There is also a less visible but decisive element: the AMLR refers many details to regulatory technical standards and AMLA guidelines. The framework applicable in 2027 will therefore consist of the Regulation together with its technical development, which is still being prepared.

The previous patchwork: 27 different transpositions

Minimum harmonisation led to substantive differences between Member States in three areas: the strictness of obligations (“gold-plating”), institutional arrangements and the timeliness of transposition. The following examples are particularly illustrative:

Country	Transposing legislation	Cash limit (payments to professionals)	Distinctive features
Spain	Law 10/2010 and Royal Decree 304/2014; AMLD5 implemented through Royal Decree-Law 7/2021.	€1,000 (€10,000 for non-resident individuals).	Highly detailed legislation; Sepblac as FIU and single supervisor; annual review by an external expert; centralised AML body for notaries; Central Register of Beneficial Ownership.
France	Code monétaire et financier, Articles L561-1 et seq.	€1,000 for residents.	Tracfin as FIU; sectoral supervision (ACPR, AMF and professional bodies); favourable 2022 FATF evaluation.
Italy	Legislative Decree 231/2007, amended in 2017 and 2019.	€5,000 (increased in 2023).	FIU integrated into the Bank of Italy; beneficial ownership register launched late and subject to litigation.
Belgium, Portugal, Netherlands	National laws adopted in 2017–2018 (Wwft in the Netherlands).	€3,000.	Intermediate limits; the Netherlands restricted access to its beneficial ownership register following the CJEU judgment of 2022.
Greece	Law 4557/2018.	€500 (transactions of this amount must be conducted through a bank).	The lowest cash limit in the Union.
Germany	Money Laundering Act (GwG), 2017.	No general limit.	More than 300 regional authorities supervise the non-financial sector, according to FATF (2022); the transparency register was not fully in place until 2021.
Austria, Ireland, Luxembourg	National transposition laws.	No statutory limit.	Strong presence of funds, private banking and special-purpose companies; Luxembourg restricted access to its register following the CJEU ruling.
Romania and Ireland	Late transposition of AMLD4.	—	On 16 July 2020, the CJEU ordered them to pay €3 million and €2 million respectively (Cases C-549/18 and C-550/18).
Bulgaria	Anti-Money Laundering Measures Act, 2018.	—	On the FATF grey list since October 2023; action plan substantially completed in June 2026, with removal expected.

These differences were compounded by the CJEU judgment of 22 November 2022 (Cases C-37/20 and C-601/20, WM and Sovim), which invalidated general public access to beneficial ownership registers. Member States responded differently: some closed access, while others made it conditional on a legitimate interest assessed on a case-by-case basis. AMLD6 now harmonises access.

Sources for this section: cash limits according to Didit (October 2026); CJEU penalties according to eucrim; access to registers according to Cyprus Mail; Germany according to OCCRP’s coverage of the FATF report; Bulgaria according to FATF (June 2026).

Who is better placed to adapt, and why

The countries best placed are those that already imposed requirements stricter than the directives and have centralised supervisors and registers: Spain, France, Belgium and Portugal. Those facing the greatest challenges are countries with high levels of cash use, fragmented supervision or weak registers—Germany in particular, along with Bulgaria and Romania.

Implementation readiness depends on two variables:

1. The substantive gap between national law and the AMLR. The stricter the national rules already were, the fewer changes obliged entities will need to make to their procedures. The cash-payment limit is the clearest indicator: in a country with a €1,000 limit, the EU-wide €10,000 cap has no practical effect; in a country with no limit, payment habits among businesses and consumers will have to change.
2. Institutional maturity. The AMLR assumes an operational FIU, supervisors able to apply AMLA technical standards, and reliable, interconnected beneficial ownership registers. Countries that already have these systems need to adapt them; others will have to build them.

Ease of AMLR implementation · qualitative assessment by Audalia Auditores

Each country’s position is a qualitative assessment based on the indicators in the table above, not a quantitative measurement.

One nuance is often overlooked: gold-plating helps obliged entities but complicates matters for legislators. A Member State that transposed the directive almost verbatim (copy-out) only needs to repeal its law. A Member State that added its own obligations must review each one to determine whether it is permitted by the AMLR, falls within the scope-extension option in Article 4, or must be removed because it conflicts with maximum harmonisation.

Applied to the countries discussed above:

• Spain and France: a €1,000 cash limit, a broad list of obliged entities and local PEPs already defined using the 50,000-inhabitant threshold in Spain. The operational effort for entities is low; the legislative effort is high.
• Italy and Greece: demanding obligations, but beneficial ownership registers that were introduced late or have been litigated. The main task concerns infrastructure, not the rules themselves.
• Austria, Ireland and Luxembourg: strong financial supervisors, but no cash limit and significant exposure in funds and private banking to the new beneficial ownership and high-net-worth-client rules.
• Germany: no cash limit, a well-established cash-payment culture and more than 300 regional supervisors for the non-financial sector. It has the longest road ahead in both areas.
• Bulgaria and Romania: a history of non-compliance (FATF grey-list status and a CJEU ruling) means that they need to strengthen their capabilities before applying a more demanding framework.

The Spanish position: little practical change, substantial legislative redrafting

Spain is well positioned in substantive terms, but its extensive national legislation will need to be reorganised. The Ministry of Economy held a public consultation, open until 30 September 2026, on the draft comprehensive measures law that will replace Law 10/2010 and establish the National Financial Integrity Authority (ANIFI), bringing together functions currently distributed among the Prevention Commission, Sepblac and other bodies. In parallel, an amendment to Royal Decree 304/2014 was processed in March–April 2026.

The main points of friction between current Spanish legislation and the AMLR are:

Area	Law 10/2010 and Royal Decree 304/2014	AMLR	Impact
Beneficial ownership threshold	More than 25%.	25% or more.	Review structures with holdings of exactly 25%.
Cash	€1,000 limit for payments to professionals.	€10,000, with lower national limits permitted.	No change: the Spanish limit remains in place.
Local PEPs	Municipalities with more than 50,000 inhabitants.	Authorities in areas with 50,000 inhabitants or more.	Minimal adjustment.
Internal organisation	Internal control body and representative before Sepblac.	Management-body-level manager and compliance manager (Article 11).	Redesign governance; the 2025 consultation had already questioned the usefulness of the internal control body.
External review	Annual review by an external expert (Article 28 of Law 10/2010).	Independent audit function (Article 9).	How the requirements will fit together remains subject to the final text of the new law.
Obliged entities	National list, broader in some sectors.	Harmonised list; national additions only on a risk basis (Article 4).	Justify each obliged entity not included in the AMLR.
New sectors	No football clubs or agents.	Included from 10 July 2029.	New obliged entities.

For Spanish obliged entities, the substantive conclusion is reassuring: most current procedures will remain valid. The risk lies in the details—customer due diligence update deadlines, documentation of beneficial ownership under the new threshold, compliance governance and, above all, the transition from Law 10/2010 to a framework combining the EU Regulation, AMLA technical standards and national legislation.

What obliged entities should do now

Less than nine months remain until 10 July 2027. A gap analysis carried out now will help spread the workload rather than concentrate it in the final quarter:

1. Confirm whether the business falls within the list in Article 3 of the AMLR, particularly if the activity is new to the regulatory framework (crypto-assets, crowdfunding, high-value goods and professional football).
2. Review beneficial ownership across the client portfolio using the “25% or more” threshold and the new rules on indirect control.
3. Recalibrate customer due diligence: the €10,000 and €3,000 cash thresholds, maximum update intervals, and enhanced measures for PEPs and high-net-worth clients.
4. Redesign compliance governance in accordance with Article 11: a manager at management-body level, a compliance manager with sufficient resources and an independent audit function.
5. Update the AML manual and risk assessment so that they refer to the AMLR and AMLA technical standards, rather than Law 10/2010 alone.
6. Monitor the progress of the new Spanish law and AMLA technical standards, which will specify many of the obligations.

At Audalia Auditores, we support obliged entities throughout this process, from gap assessments to independent reviews of their anti-money laundering systems.