EU Anti-Money-Laundering Framework: History and Current State

The European Union's anti-money-laundering and counter-terrorist-financing (AML/CFT) regime is undergoing the largest structural change in its history. For three decades it was built almost entirely on directives — instruments that bind member states as to the result but must be transposed into 27 separate national laws, producing material divergence in thresholds, register designs, supervisory structures and enforcement. The 2024 AML Package changes the instrument type: the core conduct rules now live in a directly applicable Regulation, alongside a directive governing institutional plumbing and a regulation creating a new EU-level authority.

This guide covers the bodies that make and enforce the framework, the directive timeline through the 2024 package, the current operative framework, and primary sources.

The bodies

Body	Role	Status
European Commission (DG FISMA)	Proposes AML/CFT legislation; manages the EU framework and the consolidated financial-sanctions list	Existing
National FIUs (e.g. TRACFIN in France, FIU-Nederland in the Netherlands, the FIU within German customs)	Receive and analyse Suspicious Transaction Reports (STRs); disseminate intelligence	Existing; coordination strengthened under AMLD6
National competent authorities / AML supervisors	Day-to-day supervision of obliged entities	Existing; harmonised under AMLD6
EBA (European Banking Authority)	Held the EU-level AML/CFT coordination and standards mandate from 2020	Mandate transfers to AMLA as AMLA stands up
AMLA (Authority for AML/CFT, Frankfurt am Main)	EU-level supervisor: direct supervision of selected high-risk cross-border entities; coordination of national supervisors and FIUs; drafts technical standards	New — operational from 1 July 2025; direct supervision from 2028

The 2024 reform compresses a long-standing source of complexity: where compliance once meant tracking 27 national transpositions, the new regulation establishes a single rulebook applied uniformly, with AMLA in Frankfurt as a central EU-level supervisor for the highest-risk institutions and the author of harmonised technical standards.

History timeline: 1AMLD to 6AMLD

Year	Instrument	What it introduced / changed
1991	1AMLD — Council Directive 91/308/EEC	First EU AML directive. Predicate offence limited to drug trafficking; obligations on the financial sector only.
2001	2AMLD — Directive 2001/97/EC	Broadened predicate offences to all serious crime; extended scope beyond banks to more professions (e.g. lawyers, accountants, dealers).
2005	3AMLD — Directive 2005/60/EC	Introduced the risk-based approach; separated money laundering and terrorist financing; expanded customer due diligence and the range of obliged entities; whistleblower protection.
2015	4AMLD — Directive (EU) 2015/849	Modern baseline. Reinforced the risk-based approach; introduced beneficial-ownership (BO) registers; tightened PEP rules; included tax crimes; lowered cash-transaction thresholds. Repealed 3AMLD.
2018	5AMLD — Directive (EU) 2018/843	Amended 4AMLD. Brought in virtual-asset service providers (crypto exchanges, custodian wallets) and prepaid cards; broadened access to BO registers; interconnection of registers; enhanced due diligence for high-risk third countries.
2018	6AMLD — Directive (EU) 2018/1673	Criminal-law harmonisation: common definition of money laundering, 22 predicate offences, corporate (legal-person) liability, minimum maximum penalties. Transposition deadline 3 December 2020.
2024	AML Package adopted	Three instruments published in the Official Journal: AMLR (2024/1624), AMLD6 (2024/1640), AMLA Regulation (2024/1620). See the 2024 package timeline below.

Naming note. Two distinct directives are commonly called "6AMLD": Directive (EU) 2018/1673 (the criminal-law directive) and Directive (EU) 2024/1640 (part of the 2024 package). They are best disambiguated by their CELEX/ELI numbers.

The 2024 AML Package

Instrument	Citation	Type	Enters into force	Applies / transposition
AMLA Regulation	Regulation (EU) 2024/1620	Regulation (creates EU agency, Frankfurt)	26 June 2024	AMLA operational from 1 July 2025; direct supervision from 2028
AMLR (single rulebook)	Regulation (EU) 2024/1624	Regulation (directly applicable conduct rules)	9 July 2024	Applies from 10 July 2027 (football clubs/agents: 10 July 2029)
AMLD6	Directive (EU) 2024/1640	Directive (institutional layer)	9 July 2024	Transpose by 10 July 2027; transparency-register access provisions due 10 July 2025; real-estate registers by 10 July 2029

Key milestones:

1 July 2025 — AMLA begins operations in Frankfurt, initially focused on standards-setting, coordination and staffing.
10 July 2025 — AMLD6 transparency-register (legitimate-interest access) provisions due.
10 July 2027 — AMLR applies EU-wide; AMLD6 transposition deadline.
2028 — AMLA begins direct supervision of selected high-risk obliged entities.
10 July 2029 — AMLR football-sector rules apply; AMLD6 real-estate registers due.

Current framework

The current regime combines the AMLR single rulebook, AMLD6, the AMLA authority, and a recalibrated beneficial-ownership transparency model following the Court of Justice of the EU.

AMLR single rulebook. A directly applicable Regulation setting uniform rules on customer due diligence, beneficial ownership, reporting and internal policies, removing most national discretion from the conduct layer. It applies from 10 July 2027.
AMLD6. A directive governing the institutional layer — FIUs, supervisors and registers — to be transposed by 10 July 2027.
AMLA. From 2028, AMLA directly supervises a set of selected high-risk, cross-border financial institutions and authors regulatory and implementing technical standards.
Beneficial ownership after the CJEU. 4AMLD created BO registers and 5AMLD broadened access. In its judgment of 22 November 2022 in Joined Cases C-37/20 and C-601/20 (WM and Sovim SA v Luxembourg Business Registers), the CJEU struck down the 5AMLD provision granting the general public access, holding it disproportionate under Articles 7 and 8 of the Charter. Access now requires a legitimate interest, which the 2024 package codifies. The beneficial-ownership threshold under AMLD6 is 25% or more.

Core obligations

Customer Due Diligence (CDD). Identify and verify customers and beneficial owners and conduct ongoing monitoring; apply Enhanced Due Diligence for high-risk situations (PEPs, high-risk third countries, complex or unusual transactions) and Simplified Due Diligence for lower-risk cases. The AMLR harmonises these rules directly across the EU rather than leaving thresholds to national law.
Beneficial-ownership identification. Identify and verify beneficial owners against the 25%-or-more threshold, with register access governed by legitimate interest.
Suspicious Transaction Reporting (STR). Obliged entities report suspicions to their national FIU, which analyses and disseminates. AMLD6 strengthens FIU powers and cross-border cooperation, coordinated by AMLA.
Risk-based approach. Entities calibrate controls to assessed money-laundering and terrorist-financing risk, informed by EU-level and national risk assessments.
Targeted financial sanctions. EU sanctions ("restrictive measures") are a separate legal track adopted under the Common Foreign and Security Policy, but the 2024 AML Package expressly links AML controls to the implementation of targeted financial sanctions within obliged entities' internal policies. The European Commission maintains the EU Consolidated Financial Sanctions List and publishes the EU Sanctions Map.