AMLR
The AMLR (Anti-Money Laundering Regulation) is the EU’s new anti-money laundering law that will apply across all member states from 2027.
What is the AMLR? Europe's New Anti-Money Laundering Regulation
The current Dutch Anti-Money Laundering and Counter-Terrorism Financing Act (Wwft) will be replaced in the coming years by new European AML rules. This EU AML package consists of the Anti-Money Laundering Regulation (AMLR), the Sixth Anti-Money Laundering Directive (AMLD6) and AMLAR. AMLAR regulates the establishment and operation of the new European supervisory authority AMLA. AMLA began its operations on 1 July 2025
The EU AML package introduces new obligations for financial institutions and certain non-financial industries and is aimed at strengthening the fight against money laundering and terrorist financing.
What will change under the AMLR?
It is expected that there will be an impact on many organizations, which can be managed through timely preparation. The main differences lie in the details of the new rules and regulations.
The new AML package will clarify certain points compared to the current legal framework in the Netherlands. The AMLR also sets additional requirements. In addition, new parties will fall within scope of the European AML rules. Over the next few years, we anticipate receiving more detailed guidance from AMLA.
One change in the legislative package concerns the threshold for beneficial owners, shifting from ‘more than 25%’ to ‘25% or more’. Furthermore, the AMLR stipulates that obliged entities must focus on reporting "suspicious transactions" rather than "unusual transactions", as is currently common in the Netherlands. This change requires a different approach to transaction monitoring. In addition, obliged entities must apply customer due diligence in a broader range of cases, for example when handling incidental transactions of EUR 10,000 or more, rather than the EUR 15,000 threshold under the Wwft.
For detailed insights into these changes, consult our AML Alert articles:
- From "unusual" to "suspicious" in transaction reporting
What this fundamental change means for your approach to transaction monitoring. - New AML package: harmonisation, risk-based approach and stricter requirements
An overview of the European AML framework and the main differences compared to national regulations. - More institutions under the scope of AML measures
An analysis of which sectors are brought under the AMLR – and why. - Review of outsourcing processes under the AMLR
What the AMLR means for your third parties and outsourcing relationships. - More connected parties and transactions within scope
Changes to who and what should be included in your AML assessments.
Implementation timeline: key dates
New obliged entities under the AMLR
A number of non-financial organisations fall in scope of the European AML rules
A growing number of non-financial sectors, alongside traditional financial institutions, will be subject to AML rules under the AMLR. While banks, insurers, and investment firms have long been subject to anti-money laundering obligations, the AMLR strengthens and harmonises these rules across the EU.
Additionally, several new non-financial entities will be brought into scope for the first time. These include:
- Football agents: will for example be required to conduct customer due diligence and report suspicious activities related to transfers and contracts.
- Professional football clubs: will amongst others need to perform customer due diligence and report suspicious transactions, particularly those involving investors and sponsors.
- Certain luxury goods dealers: will also become subject to due diligence and reporting obligations
- Crowdfunding service providers: currently operating under an exemption and not covered by the Wwft due to the Crowdfunding Service Regulation (ECSPR) will become obliged entities under the AMLR.
Check the sector-specific pages for more information on obligations, transition periods, and possible exemptions.
What’s next?
The EU AML package represents a major step towards a single, harmonized, risk-based anti-money laundering framework within the EU. The EU AML package will become applicable in the coming years; however it is essential for organizations to start assessing the impact on their operations now.
Whether you operate in the financial sector or are to a newly in-scope entity, preparation is key. From changes in transaction monitoring, data requirements, to new thresholds for customer due diligence and a broader definition of beneficial owners: the impact will be significant but manageable with the right approach.
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