EU Anti-Money Laundering reform is law: main innovations, new categories affected

Italy: warning issued by the European Commission for anti-money laundering compliance

On June 19, 2024, the 6th AML Directive (Directive (EU) 2024/1640 of May 31, 2024), the AML Regulation (Regulation (UE) 2024/1624 of May 31 2024)  and the AMLA Regulation (EU) 2024/1620 of May 31, 2024 (so-called “AML Package“) were published in the Official Journal of the European Union.

The main objectives of the package include:

  • reform the European Union’s AML/CFT regime.
  • uniform AML/CFT obligations and measures in the EU.
  • strengthen the supervisory system.


Purpose and Entry into Force

The VI Anti-Money Laundering Directive, which amends Directive (EU) 2019/1937 and repeals Directive (EU) 2015/849-relates to the mechanisms to be established by member states to prevent the use of the financial system for the purpose of money laundering or terrorist financing.

It enters into force on the 20th day following its publication in the Official Journal of the European Union.

Member States have a general deadline to transpose the Directive by July 10, 2027, except for:

  1. the rules regarding the registry on beneficial ownership (Articles 11-12-13-15), the transposition deadline for which is July 10, 2026; and
  2. the Single Point of Access to Real Property Information (Art. 18) whose transposition deadline is July 10, 2029.

Main points

  1. Registry of beneficial owners. It will also be accessible to persons from the public with a legitimate interest (including the press and civil society);
  2. Single Access Point of Real Estate Registries. Real Estate registries will have to be accessible to the relevant authorities through a single access point, indicating information on price, type of ownership, historical data, and encumbrances such as mortgages, judicial restrictions, and property rights;
  3. Envisioned a System of inteconnection of current account registry and criminal investigations. A centralized registry with current account information will be established to facilitate the tracking of financial flows and the detection of suspicious transactions in the investigative context.
  4. Powers of FIUs. FIUs will have immediate and direct access to financial, administrative, investigative, and tax information, information on funds and other assets frozen as a result of targeted financial sanctions, transfers of funds and transfers of crypto assets, national registries of motor vehicles, aircraft, and recreational craft, customs data, and national arms registries;
  5. Increased supervision. Each Member State will ensure that all entities required to comply with AML regulations and make suspicious transaction reports are adequately and effectively supervised.
  6. New supervisory measures. New supervisory measures are introduced for the non-financial sector, with so-called supervisory colleges.


Object and entry into force:

The Anti-Money Laundering Regulation (Regulation (EU) 2024/1624 of May 31, 2024) (or “Single Rulebook“) (AML Regulation) on the prevention of the use of the financial system for the purpose of money laundering or terrorist financing enters into force on the 20th day following its publication in the Official Journal of the European Union.

It will apply as of July 10, 2027 except that the obligated entities in Article 3(3)(n) and (o) (football agents and professional football clubs), the deadline will apply as of July 10, 2029.

Main points:

(a) Enhanced due diligence requirement in case of high net worth clients: 50 mln euros; violation of this requirement will constitute an aggravating penalty.

(b) Union-wide limit set for cash payments (maximum € 10,000) except between individuals operating in a non-professional context

(c) Due diligence, transaction monitoring and reporting requirements now extended to traders of precious metals, precious stones, yachts, motor vehicles aircraft and cultural property, professional soccer clubs.

(d) High-value goods definition introduced:

  • jewelery, gold or silver items worth more than 10,000 euros;
  • watches worth more than 10,000 euros; motor vehicles worth more than 250,000 euros or local currency equivalent;
  • aircraft worth more than 7.5 mln euros or local currency equivalent;
  • vessels with a value exceeding 7.5 mln euros or local currency equivalents.

(e) For the purpose of the definition of PEPs (politically exposed persons) the following points are clarified:

  • it includes heads of regional and local authorities, including groupings of municipalities and metropolitan regions, with at least 50,000 inhabitants;
  • it includes other important public offices provided for by member states;
  • family members“: for offices under 34(a)(i) and equivalent offices at the Union level or in a third country, brothers and sisters.

(f) Of particular importance is the identification of risk variables, governed directly by the Regulations (although this is not an exhaustive list), which can be attributed to risk variables relating to customers, risk variables relating to products, services or operations, and risk variables relating to distribution channels

(g) finally, indicative factors of low risk are enumerated.

AMLA Regulation

Regulation (EU) 2024/1620 of May 31, 2024, establishing the Anti-Money Laundering and Anti-Terrorist Financing Authority (AMLA) and amending Regulations (EU) No. 1093/2010, (EU) No. 1094/2010, and (EU) No. 1095/2010, will enter into force on the seventh day following its publication in the Official Journal of the European Union, but will apply as of July 1, 2025.