AMLD – EU Anti-Money Laundering Directives (1st to 6th AMLD)

The EU Anti-Money Laundering Directives (AMLD) have formed the central harmonised EU regulatory framework for combating money laundering and terrorist financing since 1991. They are continuously updated and aligned with international standards — in particular the FATF Recommendations.

• 1st AMLD (1991): First pan-European framework, focus on drug proceeds; basic KYC obligations for banks.
• 2nd AMLD (2001): Extension to non-bank sectors (lawyers, notaries, accountants, real estate agents, casinos).
• 3rd AMLD (2005): Implementation of 2003 FATF Recommendations; risk-based approach, PEP rules, EDD/SDD.
• 4th AMLD (2015): Strengthened risk-based approach, national BO registers, expanded obligated entities.
• 5th AMLD (2018): Virtual currencies, public BO registers, enhanced due diligence for high-risk third countries, anonymous prepaid cards.
• 6th AMLD (2021): Harmonised predicate offence catalogue, minimum penalties, extended predicate offences, liability of legal persons.

The first Anti-Money Laundering Directive (91/308/EEC) of 1991 was the European response to the recommendations of the FATF founded in 1989 and was largely limited to banks and drug proceeds. The 2nd AMLD (2001/97/EC) extended the scope to additional professional sectors. The 3rd AMLD (2005/60/EC) implemented the revised FATF 40 Recommendations of 2003 and introduced the risk-based approach.

The 4th AMLD (2015/849/EU) and 5th AMLD (2018/843/EU) responded to the Panama Papers, terrorist attacks and crypto developments. The 6th AMLD (2018/1673/EU, applicable from 2021) harmonised the criminal law framework. The EU is currently working on a comprehensive AML reform package (AML Regulation, AML Directive, AMLA) intended to replace the AMLD with a directly applicable regulation.

The AMLDs apply to all 27 EU member states. Obligated entities include: credit institutions, financial institutions, lawyers, notaries, auditors, tax advisers, real estate agents, gambling operators, crypto-asset service providers (since 5th AMLD), high-value goods dealers (for cash transactions above EUR 10,000) and trustees. The directives cover money laundering from a broad range of predicate offences as well as terrorist financing.

• Risk-based approach: conduct of entity-level ML/TF risk assessments and corresponding measures.
• Customer Due Diligence (CDD): identification and verification of customers and beneficial owners (KYC).
• Enhanced Due Diligence (EDD): heightened measures for high-risk customers, PEPs and high-risk third countries.
• Suspicious Activity Reports (SARs) to the national Financial Intelligence Unit (FIU).
• Maintenance and retention of records for at least five years.
• Implementation of AML/CFT internal control systems, training and compliance officers.

1 update:
- AMLD: Missing successor reference to AMLR, EU AML Package 2024 dates incomplete