Technical Alert TA 05/2025 - Outline of selected changes under the European Union 6th Anti Money Laundering Package

From the Technical Accounting team …

Members and readers may be aware that the European Anti Money Laundering Authority (AMLA) commenced its work this year. Part of its remit is to provide regulatory technical standards (RTSs) and guidelines for both financial and non-financial obliged entities on areas dealt with in the AML Regulation and AML Directive, the European Union 6th Anti-Money laundering package, informally known as AMLD6. These laws were passed in 2024 but most of the provisions do not come into force until 2027. The provisions apply to all obliged entities including accountants, auditors, and tax advisors.

As AMLA’s work continues over the coming years (throughout 2026 and 2027), the Institute will monitor and distribute more information and guidance of interest and importance to members in the anti-money laundering area. In the meantime, we have prepared Technical Alert 05/2025, which outlines selected changes to current AML law under AMLD6.

The Alert provides a high-level outline of some of the changes which will occur when AMLD6 comes into force in 2027. While this seems like a relatively long time away, it will pay to gain an early insight and understanding of the changes prior to provisions coming into force.

The Alert highlights differences from current law, which are likely to be of most relevance or interest to our members. It is a comparison document rather than specific or detailed instructions or guidance on AMLD6. Nonetheless, we hope that it will provide some useful information for our members in gaining further understanding of the new compliance requirements under the AMLD6 package.

Some of the changes, which members should take note of include:

• More detailed requirements for customer due diligence (CDD) procedures.
• EU Ban on cash payments over €10,000. Individual member states may set even lower limits.
• More closely defined AML roles, governance structures, and internal control framework.
• An independent audit function within entities or the possibility to outsource this to an external expert. This may pose challenges for sole practitioners, and it is going to be an additional cost of being in practice (where independent audit functions do not currently exist).
• New outsourcing rules and outsourcing prohibitions.
• Wider definition of a Politically Exposed Person (e.g. to include the siblings of PEPs in certain cases).
• More detailed beneficial ownership provisions.

The Institute will continue to keep track of AMLA’s work and deliverables over the coming months.

This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.