The New EU AML Package

The European Union is establishing a stricter and more centralised anti-money laundering framework. The new rules affect banks, payment service providers, crypto companies, legal and corporate services, as well as other business sectors involved in financial transactions and asset structuring. For clients, this means more thorough checks. For companies, it means increased requirements for internal controls, documentation and risk management. ELI Swiss provides consultancy services in the field of international business and assists clients in taking regulatory requirements into account when establishing and managing corporate structures. The EU AML/CFT Package was adopted in 2024, with its provisions entering into force and becoming applicable in stages. The reform includes a new EU-wide regulation, an updated directive and the establishment of a specialised body – the European Authority for Anti-Money Laundering and Countering the Financing of Terrorism, or AMLA.

Restrictions on cash transactions

The new package introduces a pan-European limit on large cash transactions. The AML Regulation establishes an EU-wide €10,000 limit on cash payments, while allowing Member States to maintain or introduce lower national thresholds where permitted by EU law. The aim of the measure is to reduce the possibility of using large sums of cash to conceal the origin of funds. The restrictions primarily affect commercial transactions. However, specific rules may depend on the nature of the transaction and the legislation of the country in question. Companies dealing with international clients must take into account the requirements of the country in which the transaction takes place. Breaching these restrictions may lead to audits and further enquiries from regulatory authorities.

AMLA’s new role

The establishment of AMLA was a central element of the reform. The new body is based in Frankfurt and is tasked with coordinating AML/CFT supervisory activities at EU level. From onwards, AMLA will gradually assume specific supervisory and coordination responsibilities that were previously exercised, in part, by the European Banking Authority (EBA), while also taking on new powers under the EU AML framework. The authority will participate in the development of uniform standards, coordinate national authorities and promote a more consistent application of requirements. The AMLA will also be granted powers to directly supervise certain high-risk financial institutions. This primarily concerns large cross-border entities. For other market participants, supervision will be carried out by national authorities, coordinated by the AMLA. The establishment of a single supervisory centre is expected to bridge the gap between the requirements of different countries and improve the efficiency of information exchange.

Tighter requirements for KYC and beneficial ownership checks

Customer due diligence remains one of the key tools of AML control. Companies must identify and verify a customer’s identity, understand the nature and purpose of the business relationship, and determine the ultimate beneficial owners (UBOs) who ultimately own or control the legal entity. Under the new regime, the importance of verifying ultimate beneficial owners is increasing. A formal designation of the company’s owner may not be sufficient. Financial institutions and other obliged entities assess the ownership structure, sources of funds and the economic purpose of transactions. Particular attention is paid to complex corporate structures. The use of multiple companies is not in itself a breach. However, the structure must have a clear business rationale. If the purpose of the companies cannot be explained or the documents contain contradictory information, this may lead to further scrutiny.

Restrictions on cash transactions

The new package introduces a pan-European limit on large cash transactions. The AML Regulation establishes an EU-wide €10,000 limit on cash payments, while allowing Member States to maintain or introduce lower national thresholds where permitted by EU law. The aim of the measure is to reduce the possibility of using large sums of cash to conceal the origin of funds. The restrictions primarily affect commercial transactions. However, specific rules may depend on the nature of the transaction and the legislation of the country in question. Companies dealing with international clients must take into account the requirements of the country in which the transaction takes place. Breaching these restrictions may lead to audits and further enquiries from regulatory authorities.

Uniform rules across the European Union

One of the key changes has been the introduction of the Anti-Money Laundering Regulation (AMLR). The regulation applies directly in all EU Member States. This approach reduces regulatory fragmentation between Member States, promotes greater consistency in AML/CFT supervision, and limits opportunities for regulatory arbitrage. Previously, Member States implemented the provisions of directives through their own legislation. As a result, requirements for customer due diligence, risk assessment and transaction monitoring could vary. The new approach aims to create a common framework in which the basic rules apply uniformly across the entire EU. For businesses, this means they must take into account not only local legislation but also pan-European standards.

Preparing for the new requirements

Companies are advised to review their corporate documents, details of their owners and information on their business activities in advance. It is essential to ensure that the data provided to banks, registrars and other organisations is consistent. Companies should maintain documentation demonstrating the lawful source of funds and, where appropriate, the source of wealth, as financial institutions may request evidence supporting both during customer due diligence procedure. Depending on the situation, these may include financial statements, contracts, documents relating to the sale of assets or other supporting evidence. It is also necessary to assess internal control procedures. Companies subject to AML/CFT requirements must have mechanisms in place for customer due diligence, risk assessment and the detection of suspicious transactions. The new EU package changes more than just the formal rules. It reinforces the importance of transparency and makes compliance an integral part of a business’s day-to-day operations.

AML/CFT reform requires taking into account EU regulations, national legislation and the requirements of financial institutions simultaneously. Errors in the preparation of the corporate structure or documentation may lead to delays in opening an account, additional checks and restrictions on transactions. ELI Swiss provides services in the areas of international business registration and support, corporate structuring and advisory support. We help you assess the requirements of a specific jurisdiction, prepare your corporate structure and take into account factors that may affect the outcome of compliance checks. If you would like more detailed information on the EU’s new anti-money laundering package or require professional support for an international project, please contact ELI Swiss. Our specialists will help you analyse your requirements and determine the best course of action.

FAQ

What does the new EU anti-money laundering package include?

The package includes a single regulation on anti-money laundering, a new AML directive, rules for specific business sectors, and the establishment of the European Anti-Money Laundering Authority. The reform aims to harmonise requirements across all EU countries and strengthen oversight of financial transactions.

When will the new rules come into force?

The reform is being implemented in stages. The EU AML Package is being introduced in stages. AMLA became operational in 2025, while most provisions of the AML Regulation (AMLR) and the Sixth Anti-Money Laundering Directive (AMLD6) will become applicable from July 2027. Certain requirements will apply on different dates depending on the relevant legislative instrument and the category of obliged entity. Certain provisions may be introduced at different times, depending on the type of activity and national legislation.