On 10 July 2027, Regulation (EU) 2024/1624 (the EU Anti-Money Laundering Regulation, AMLR) will begin to apply across all 27 EU Member States. With less than a year remaining, licensed financial institutions should already be reviewing their AML frameworks and implementation plans. Unlike previous AML directives, AMLR is a regulation, meaning it applies directly without national transposition and introduces one harmonised rulebook for the entire European Union.
This article explains what will change for EMIs, payment institutions and CASPs, and outlines a practical quarter-by-quarter roadmap to prepare before the deadline. Rather than waiting for the final technical standards, firms should already begin reviewing their governance, AML documentation and operational processes to ensure they are ready before the Regulation applies.
#One Rulebook Instead of 27: AMLR, AMLD6 and AMLA
The EU's new AML package consists of three separate legal acts, each serving a different purpose. Understanding the distinction is essential because they apply in different ways.
AMLR (Regulation (EU) 2024/1624) establishes a single set of AML obligations for obliged entities across the European Union, including customer due diligence, beneficial ownership, internal controls and reporting requirements.
AMLD6 (Directive (EU) 2024/1640) governs matters that remain at national level, including beneficial ownership registers, Financial Intelligence Units (FIUs) and the powers of national supervisors. Member States must transpose the Directive by 10 July 2027.
The AMLA Regulation (Regulation (EU) 2024/1620) establishes the new Anti-Money Laundering Authority (AMLA) in Frankfurt. AMLA became operational on 1 July 2025 and assumed the European Banking Authority's AML responsibilities on 31 December 2025.
Together, these measures significantly reduce national differences in AML compliance. As supervisory practices become increasingly harmonised, choosing a Member State based primarily on a perceived "lighter" AML regime will become far less effective as a regulatory strategy.
#AMLR Timeline: AMLA Deadlines and the 2027 Application Date
Four key milestones define the preparation period for AMLR implementation.
- 10 July 2026 – AMLA is delivering the main package of Regulatory Technical Standards (RTS), Implementing Technical Standards (ITS) and guidelines to the European Commission. At the time of publication, AMLA's Regulatory Instruments programme shows a combination of final reports, closed consultations and ongoing consultations, with several technical standards scheduled for completion later in 2026.
- 1 July 2027 – AMLA begins selecting companies for direct supervision, with the selection process expected to take approximately six months.
- 10 July 2027 – AMLR becomes directly applicable across the European Union, and Member States must complete the transposition of AMLD6.
- From 2028 – AMLA begins directly supervising approximately 40 selected high-risk obliged entities operating across multiple Member States.
#What Changes for Every Obliged Entity
AMLR introduces several changes that apply across almost all obliged entities, regardless of whether they operate as a bank, EMI, payment institution or CASP.
Customer Due Diligence (CDD). The threshold for applying customer due diligence to occasional transactions is reduced from €15,000 to €10,000. The new threshold applies both to a single transaction and to multiple linked transactions that together reach the limit.
Beneficial Ownership. AMLR changes the ownership threshold from "more than 25%" to "25% or more", meaning a shareholder holding exactly 25% now qualifies as a beneficial owner. The European Commission may reduce this threshold to 15% for higher-risk sectors. Where no beneficial owner can be identified under the applicable threshold, the senior managing official must be treated as the beneficial owner. Obliged entities must also compare customer due diligence information against central beneficial ownership registers and report any discrepancies.
Cash Payments. AMLR introduces an EU-wide €10,000 limit on cash payments, although Member States may choose to apply lower national limits.
Administrative Sanctions. For serious, repeated or systematic breaches by credit and financial institutions, AMLR provides for maximum administrative pecuniary sanctions of at least €10 million or 10% of annual turnover, whichever is higher.
#What Changes for CASPs
Crypto-asset service providers remain subject to the general AMLR obligations, but several requirements apply specifically to crypto activities. Under Article 19 AMLR, the customer due diligence threshold for occasional crypto-asset transactions is €1,000, substantially lower than the general €10,000 threshold. Even below that amount, CASPs must still identify and verify their customers where required by the Regulation.
AMLR also introduces stricter requirements for transfers involving self-hosted addresses. Depending on the circumstances, CASPs must apply appropriate mitigating measures, including identifying the originator and beneficiary, obtaining additional information about the origin and destination of crypto-assets, and applying enhanced monitoring to higher-risk transactions.
In addition, Article 79 AMLR extends the prohibition on anonymous accounts to crypto-asset accounts and anonymisation-enhancing instruments.
Importantly, MiCA authorisation does not mean a CASP is automatically prepared for AMLR compliance. MiCA and AMLR establish separate regulatory regimes with different obligations and supervisory expectations. Businesses reviewing their options after the end of MiCA grandfathering should also ensure that the AML/CFT section of their CASP licence application reflects the new AML framework before July 2027.
#What Changes for EMIs and Payment Institutions
For electronic money institutions (EMIs), payment institutions (PIs) and small payment institutions (SPIs), AMLR marks the transition from nationally interpreted AML requirements to a single European rulebook. In practice, this means AML obligations become increasingly consistent across Member States. A comparatively accessible licensing regime, such as the Polish SPI framework, should no longer be viewed as implying lighter AML compliance obligations.
AMLR also narrows the circumstances in which simplified customer due diligence measures may apply to electronic money. Rather than relying on broad national exemptions, firms will increasingly follow risk factors specified by AMLA through technical standards, reducing the scope for national differences.
Finally, EU parent companies become responsible for ensuring group-wide AML policies and controls across all subsidiaries and branches, including operations established in third countries. Businesses operating under an EMI licence in Malta or another EU jurisdiction should therefore review both their governance framework and existing group AML arrangements well before the Regulation becomes applicable.
#How to Prepare for AMLR: Compliance Roadmap to July 2027
With less than a year before AMLR becomes directly applicable, the remaining preparation period can be divided into four practical stages.
Q3 2026 — Perform a gap analysis. Review existing AML policies and procedures against the text of AMLR itself, rather than current national legislation, which will no longer be the primary reference from July 2027. At the same time, monitor the publication of AMLA's final Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS).
Q4 2026 — Update governance and risk assessments. Refresh your business-wide risk assessment, review beneficial ownership records under the new "25% or more" threshold, and assess whether outsourcing arrangements and group structures remain compliant with AMLR.
Q1 2027 — Rewrite policies and train staff. Update internal AML documentation using AMLR terminology, revise customer onboarding procedures to reflect the new due diligence thresholds, and ensure compliance teams understand the revised regulatory framework before implementation.
Q2 2027 — Test and implement. Obtain board approval, perform operational testing, complete staff readiness checks and place the updated AML framework into operation before 10 July 2027.
Some AMLA technical standards may still be awaiting formal adoption by the European Commission during this period. Firms should therefore prepare on the basis of the AMLR text itself, refining individual policies as final RTS become available.
If you are planning your AMLR implementation, our AML readiness support for licensed payment institutions helps SPI, EMI and CASP licence holders perform gap analyses, update AML documentation and prepare their compliance framework before July 2027.
#The Bottom Line
AMLR gives licensed financial institutions a clear implementation timeline, but twelve months can pass quickly for firms with complex governance structures or cross-border operations. Businesses that begin with a structured gap analysis now will have sufficient time to update policies, systems and internal controls before 10 July 2027. Waiting for every technical standard or national measure to be finalised is likely to leave significantly less time for implementation.
If you are preparing for AMLR, our AML readiness support for licensed payment institutions helps SPI, EMI and CASP licence holders perform gap analyses, update AML documentation and prepare their compliance framework before 10 July 2027.
#FAQ
#When does the new EU AML Regulation (AMLR) apply?
The EU Anti-Money Laundering Regulation (AMLR) applies from 10 July 2027. Unlike previous AML directives, it applies directly across all 27 EU Member States without national transposition. The same date is also the deadline for Member States to transpose AMLD6 into national law.
#What is the new CDD threshold for occasional transactions under AMLR?
For most obliged entities, AMLR lowers the customer due diligence threshold for occasional transactions from €15,000 to €10,000, including linked transactions. For CASPs, the threshold is €1,000, while customer identification and verification remain mandatory in situations specified by the Regulation even below that threshold.
#Will AMLA supervise my company directly?
Probably not. From 2028, AMLA will directly supervise around 40 selected high-risk obliged entities operating in six or more EU Member States. Most firms will continue to be supervised by their national authority while applying the same harmonised AML rulebook established by AMLR.
#Can Equilex help prepare for AMLR compliance?
Yes. Equilex supports SPI, EMI and CASP licence holders with AML gap analyses, updates to AML policies and procedures, regulatory documentation and implementation planning. Where appropriate, we also advise on licensing and jurisdictional strategies to support long-term regulatory compliance.