EU AML Regulations (AMLD/AMLR)¶
Definition¶
The EU's AML framework has evolved through successive Anti-Money Laundering Directives (AMLD) and now the AML Regulation (AMLR 2024) — directly applicable across all member states.
Evolution¶
| Regulation | Year | Key Change |
|---|---|---|
| 3AMLD | 2005 | Risk-based approach introduced |
| 4AMLD | 2015 | UBO registers, risk assessment requirements |
| 5AMLD | 2018 | Virtual currencies covered, public UBO registers |
| 6AMLD | 2020 | Harmonized predicate offenses, aiding/abetting criminalized |
| AMLR | 2024 | Single rulebook — directly applicable regulation (not directive) |
| AMLA | 2024 | New EU-level AML Authority (Frankfurt) |
AMLR 2024 Key Changes¶
| Change | Impact on eKYC |
|---|---|
| Direct regulation | Same rules across all 27 states — no more national interpretation differences |
| AMLA | New EU-wide supervisor for largest cross-border FIs |
| Cash limit €10,000 | EU-wide cash payment limit |
| Crypto full scope | All CASPs subject to same KYC as banks |
| UBO threshold 25% | Harmonized across EU |
| Enhanced CDD | Standardized EDD triggers across EU |
| Third-country policy | Unified high-risk third country list |
Key Takeaways¶
Summary
- EU AML is shifting from directives (national implementation) to regulation (directly applicable)
- AMLA creates EU-level supervision for the first time — Frankfurt-based authority
- AMLR 2024 standardizes KYC requirements across all 27 member states
- Crypto fully included — CASPs face same KYC obligations as traditional finance
- eKYC providers serving EU can now build one compliance framework instead of 27