The EU’s Anti-Money Laundering Package Is Here — What AMLD6 Means for Your Entity Management

If you manage legal entities across Europe, the EU’s new Anti-Money Laundering Package, commonly referred to as AMLD6, deserves your attention now. The EU adopted it on 31 May 2024 as Directive (EU) 2024/1640, and it forms one part of a broader legislative overhaul. Together with a new regulation and a new authority, it replaces more than a decade of fragmented AML directives with a tighter, more unified framework. The full application date is 10 July 2027, but the groundwork is already underway.

Wait — is AMLD6 one thing or three?

Good question, and worth clearing up early. When people say “AMLD6,” they often mean the entire 2024 AML Package. That package actually consists of three distinct pieces of legislation:

• Directive (EU) 2024/1640 (the Sixth Anti-Money Laundering Directive, or AMLD6 proper). As a directive, each EU Member State must transpose it into national law by 10 July 2027. It covers the institutional side: how national supervisors operate, the structure and powers of Financial Intelligence Units (FIUs), beneficial ownership registers, and cross-border cooperation.
• Regulation (EU) 2024/1624 (the Anti-Money Laundering Regulation, or AMLR). As a regulation, it applies directly across all 27 Member States. No national transposition needed. It’s the “single rulebook” for obliged entities: customer due diligence (CDD), internal controls, suspicious transaction reporting, and beneficial ownership transparency. It also applies from 10 July 2027.
• Regulation (EU) 2024/1620 (the AMLA Regulation). This creates the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), headquartered in Frankfurt. AMLA has been operational since 1 July 2025. It will directly supervise around 40 of Europe’s highest-risk financial institutions and coordinate national FIUs.

A fourth text completes the framework: the Transfer of Funds Regulation (Regulation (EU) 2023/1113), also known as the Travel Rule. It requires traceability for all crypto-asset transfers within the EU.

So when someone mentions “AMLD6,” they might mean the directive specifically or the entire package. Context matters.

How did things work before?

Up until now, Europe’s anti-money laundering framework relied on directives, primarily AMLD4 (Directive (EU) 2015/849) as amended by AMLD5 (Directive (EU) 2018/843). Each Member State had to pass its own laws to implement the requirements, and that’s exactly where problems cropped up. Different countries interpreted obligations differently, set different thresholds, and supervised their obliged entities with varying levels of rigour.

For multinational companies managing entities across several EU jurisdictions, this created a patchwork of rules. Your Dutch subsidiary and your French subsidiary might both carry AML obligations. But the specific procedures, filing requirements, and supervisory expectations could diverge in meaningful ways.

The new package aims to fix that.

What’s actually changed?

Let’s walk through the key changes that matter most for legal entity management and corporate governance teams.

• A single, directly applicable rulebook. The AMLR replaces 27 separate national transpositions with one set of rules. Customer due diligence, beneficial ownership verification, enhanced due diligence for high-risk situations, and reporting obligations now follow one standard across the EU. If your organisation operates entities in multiple Member States, you’ll eventually work from the same compliance playbook everywhere.
• The UBO threshold has dropped. Under the previous rules, a person qualified as an ultimate beneficial owner (UBO) if they held more than 25% of the shares or voting rights in a company. The new AMLR (Article 52) lowers that to 25% or more. It sounds like a small shift, but it captures individuals who sit right at the 25% mark. More people will now qualify as UBOs and require disclosure. For companies with evenly distributed ownership, this could trigger an immediate reassessment of shareholder registers.
• A €10,000 cap on business cash payments. The AMLR sets a Europe-wide limit of €10,000 for cash payments in the business sector (Article 59). Anything above that must go through traceable payment methods. On top of that, obliged entities must verify and identify customers for cash transactions of €3,000 and above.
• More businesses now fall within scope. The list of obliged entities has grown. Beyond credit institutions, financial institutions, and professional services firms, the AMLR now explicitly covers crypto-asset service providers (CASPs) authorised under MiCAR, crowdfunding platforms, professional football clubs and agents, and traders in luxury goods including precious metals and gemstones.

What about beneficial ownership registers and enforcement?

• Stronger beneficial ownership registers. AMLD6 significantly strengthens the rules on central beneficial ownership registers. National registers must hold more detailed information and cover a wider range of legal arrangements, including non-EU entities with links to a Member State. They must also interconnect via the European Central Platform (under Directive 2017/1132) and the BORIS system for cross-border checks. Authorities and obliged entities retain full access. Journalists and civil society organisations with a demonstrable legitimate interest can also request access under harmonised criteria.
• Higher sanctions for non-compliance. AMLD6 doubles the maximum pecuniary sanctions for serious, repeated, or systematic breaches: from EUR 5 million or 5% of total annual turnover to EUR 10 million or 10% of total annual turnover (whichever is higher). National supervisors also gain clearer minimum administrative measures and the power to impose periodic penalty payments to compel compliance.
• Stronger FIU powers and cooperation. Financial Intelligence Units across the EU gain expanded mandates under AMLD6. That includes clearer rules on their analytical functions, their ability to suspend or withhold consent on suspicious transactions, and a requirement to designate a Fundamental Rights Officer. AMLA will issue guidelines and coordinate cross-border information sharing between FIUs.

What about the timeline?

Here’s the thing: even though most obligations don’t take full effect until 10 July 2027, the regulatory machinery is already moving. The timeline is staggered, and several milestones have already passed or are fast approaching.

Already in effect: AMLA became operational on 1 July 2025. Certain AMLD6 provisions on beneficial ownership register accessibility (Article 74) had a transposition deadline of 10 July 2025. Articles 11–13 and 15, which also concern beneficial ownership registers, carry a transposition deadline of 10 July 2026.

By 10 July 2026: AMLA must publish 23 technical standards: regulatory technical standards (RTS), implementing technical standards (ITS), and guidelines. These cover everything from risk-based supervision to CDD requirements for newly covered sectors. The European Commission must also adopt delegated acts with more granular UBO-related penalty guidelines by this date.

By 10 July 2027: The AMLR takes full effect and Member States must finish transposing AMLD6. All obliged entities must be fully compliant. At this point, AMLD4 and AMLD5 will be formally repealed.

By 10 July 2029: Member States must have AMLD6’s provisions on the single access point to real estate information (Article 18) and the bank account registers interconnection system (BARIS) in place.

That makes 2026 the preparation year and 2027 the compliance year. Waiting until 2027 to begin readiness work is not a realistic option.

So what should you do now?

For teams managing entity portfolios across Europe, the new AML Package demands a structured response. Here are the practical steps to consider.

1. Review your UBO data. The lowered threshold means additional individuals may now qualify as beneficial owners. Reassess shareholder structures and update your UBO registers accordingly. Pay particular attention to companies where ownership splits evenly or near-evenly.
2. Run a gap analysis. Compare your current AML policies, processes, and internal controls against the AMLR requirements. Identify where your existing procedures differ from the new uniform standard. This matters especially if you operate entities in multiple EU Member States where local transpositions have created varied practices.
3. Track the technical standards. AMLA is publishing its RTS, ITS, and guidelines throughout 2026. These add critical detail to the AMLR’s high-level requirements, particularly around CDD, risk assessments, and sector-specific guidance. Monitor publication dates and factor them into your compliance planning.
4. Prepare for register obligations. If your entities fall under beneficial ownership registration requirements, make sure your data is complete, accurate, and formatted for the new standards. The interconnection of national registers will make inconsistencies between jurisdictions far more visible.
5. Strengthen internal governance. The AMLR requires obliged entities to appoint a dedicated compliance manager, distinct from existing compliance officers. This person must ensure that policies align with the entity’s risk exposure and that adequate resources are in place. Consider your organisational structure now.
6. Monitor national transposition. While the AMLR applies directly, each Member State must still transpose AMLD6. The specifics of national supervisory powers, FIU structures, and penalty regimes depend on how each country implements the directive. Keep an eye on legislative developments in your relevant jurisdictions.

What’s next?

Managing AML compliance across multiple jurisdictions requires detailed planning and full legal awareness. For more insights into compliance processes in other jurisdictions, explore our article, LETA Switzerland Register: Beneficial Ownership Guide.

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• Request a Demo – See Klea in action for your organisation.
• Start a Trial – Experience firsthand how automation reduces workload and improves efficiency.
• Talk to Our Experts – Get tailored recommendations based on your entity management needs.

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