EU AML Package 2021 (Comprehensive EU Anti-Money Laundering Reform)
EU AML Package 2021: four legislative proposals (AMLR, new AMLD 2024/1640, AMLA, TFR) — a fundamental overhaul of the EU anti-money laundering framework.
Summary
The EU AML Package was presented by the European Commission on 20 July 2021 and represents the most comprehensive reform of EU anti-money laundering law since its inception. It comprises four legislative measures that together create a consolidated, harmonised, and enforceable legal framework backed by a new EU authority (AMLA).
- AMLR (Anti-Money Laundering Regulation, Regulation 2024/1624): A unified, directly applicable EU rulebook — replacing national implementing laws of previous directives
- New AMLD (Directive (EU) 2024/1640): Complementary directive for aspects requiring national transposition — replaces AMLD4/AMLD5 (not to be confused with the 2018 6AMLD)
- AMLA Founding Regulation (Regulation 2024/1620): Establishment of the new EU anti-money laundering authority as central supervisor
- Funds Transfer Regulation (TFR, Regulation 2023/1113): Revised rules for accompanying funds transfers, including crypto-assets
History
The EU AML Package was the Commission's response to a series of serious money laundering scandals at European banks (Danske Bank, Swedbank, ABLV, Pilatus Bank) and to criticism from the European Court of Auditors (Special Report 01/2019: 'Fighting money laundering in the EU banking sector: efforts to address money laundering were mainly reactive and fragmented') and the European Parliament regarding the fragmented implementation of previous directives. An evaluation (Supranational Risk Assessment 2019) had revealed significant gaps in AML supervision at EU level. The Commission's July 2021 proposal was negotiated over several years of trilogue discussions between the Council, Parliament, and Commission, resulting in the adoption of all four measures in 2024.
Scope
The AML Package affects all EU member states and extends across all four instruments: The AMLR applies directly without national transposition to all obliged entities (financial institutions, crypto-asset service providers, notaries, lawyers, accountants, real estate agents, casinos, and others); the new AMLD (Directive 2024/1640) requires national implementation by 10 July 2027; the AMLA Regulation establishes direct supervision over selected high-risk institutions and indirect supervision over national authorities; the TFR applies to all payment service providers and crypto-asset service providers.
Key Requirements
- Directly applicable unified AML rulebook (AMLR, Regulation 2024/1624) without scope for national divergence
- Establishment of AMLA as new EU anti-money laundering authority with direct supervisory powers over selected institutions
- Expansion of obliged entities to include crypto-asset service providers (CASPs)
- Harmonised beneficial ownership registers and cross-border data access
- Stricter PEP rules and high-risk country lists
- Revised Funds Transfer Regulation (TFR, Regulation 2023/1113): Travel Rule extended to crypto-assets
- EU-wide cash payment ceiling of EUR 10,000 for commercial transactions (Art. 59 AMLR)
Related Frameworks
Corrections & Errata
3 corrections:
- TFR entry-into-force date wrong: 28 June 2023 instead of correct 29 June 2023
- Confusion '6AMLD' — refers to new AMLD (Directive 2024/1640), not the 2018 6AMLD
- Status 'proposed' incorrect — package was formally adopted in 2024
3 updates:
- Missing key_dates: AMLR application date (10 July 2027) and AMLD transposition deadline
- Missing key_date: Council adoption on 30 May 2024
- Missing key_date: Commission AML Action Plan May 2020
2 clarifications.
2 notes.