AMLR checklist by obliged entity, with the article behind every line
Blog post from Didit
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Regulation (EU) 2024/1624, the EU Anti-Money Laundering Regulation (AMLR), will apply directly across Member States from 10 July 2027, with football agents and professional clubs covered from 10 July 2029, replacing national rules derived from the current directive after the transition period. It applies to credit and financial institutions, including crypto-asset service providers, and specified professionals and traders such as lawyers, estate agents, gambling operators, crowdfunding platforms, and high-value-goods dealers, while a EUR 10,000 cash-payment cap broadly applies even to businesses that are not obliged entities. All covered organisations must implement risk-based controls including documented risk assessments, approved policies, compliance roles, customer due diligence, beneficial-ownership checks, sanctions and politically exposed person screening, transaction monitoring, FIU reporting, record retention, staff training, and outsourced-provider oversight. Sector-specific rules establish different thresholds and duties, including EUR 1,000 for certain payment and crypto transfers, EUR 2,000 for gambling transactions, EUR 3,000 for cash identification, and EUR 10,000 for general occasional transactions, alongside tailored requirements for areas such as virtual IBANs, self-hosted crypto wallets, real estate, and high-value assets. Draft technical standards from the EU Anti-Money Laundering Authority may add detail but are not yet law, and although software can support verification, screening, monitoring, and evidence collection, firms remain responsible for risk decisions, customer acceptance, FIU reporting, and compliance liability.
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