European Union AML regulations

Overview of EU AML regulations

The European Union has undergone a fundamental transformation of its AML framework with the adoption of the 2024 AML legislative package. This replaces the directive-based approach with a directly applicable regulation (the EU AML Regulation) and establishes the Anti-Money Laundering Authority (AMLA) as a centralised supervisory body.

The single rulebook

The EU AML Regulation directly applies in all member states without transposition, eliminating the inconsistencies that previously arose. Key harmonised requirements include:

• CDD requirements: Standardised across all 27 member states
• Beneficial ownership thresholds: 25% ownership uniformly applied
• Cash payment limit: EUR 10,000 across the EU
• EDD triggers: Harmonised list of high-risk factors

AMLA: centralised supervision

AMLA, headquartered in Frankfurt, has direct supervisory powers over high-risk obliged entities and coordinates national supervisors. For a detailed analysis, see our article on what AMLA means for non-financial institutions.

EU sanctions framework

EU restrictive measures are adopted by the Council under the Common Foreign and Security Policy. The EU Sanctions Map provides a consolidated view. Post-Brexit, the UK and EU sanctions regimes have diverged, requiring businesses with exposure to both jurisdictions to screen against both lists.

DNFBP obligations

EU non-financial institutions face the same core obligations as in the UK: CDD, sanctions screening, suspicious transaction reporting, and record-keeping. The single rulebook means these obligations are now consistent across all member states. Art dealers and crypto asset service providers are explicitly included in the scope.