What Is the 6th EU Anti-Money Laundering Directive?

6AMLD refers to two different EU instruments. In its original sense it is Directive (EU) 2018/1673, which criminalises money laundering across 22 categories of predicate offence. Since 2024 the label is also used for Directive (EU) 2024/1640, the mechanisms directive that member states must transpose by 10 July 2027.

Key takeaways

• Directive (EU) 2018/1673 of 23 October 2018 had to be transposed by 3 December 2020 and requires a maximum term of imprisonment of at least four years for the main laundering offences.
• Article 2(1) of that directive lists 22 categories of criminal activity, naming environmental crime, cybercrime and tax crimes among them.
• Directive (EU) 2024/1640 carries the AMLD6 label on EUR-Lex, has a general transposition deadline of 10 July 2027, and repeals Directive (EU) 2015/849 from the same date.
• Regulation (EU) 2024/1624 applies directly from 10 July 2027, with professional football clubs and agents brought in from 10 July 2029.
• Article 55 of Directive (EU) 2024/1640 sets maximum pecuniary sanctions of at least EUR 10 000 000 or 10 per cent of total annual turnover for a credit or financial institution.

Which instrument does 6AMLD actually refer to?

Both, depending on who is speaking. The criminal law directive of 2018 was the sixth AML directive in sequence, and the term stuck. When the 2024 package arrived, EUR-Lex applied the short title AMLD6 to Directive (EU) 2024/1640, and vendor material followed.

The distinction is not cosmetic. One instrument tells national legislators how to write criminal offences; the other rebuilds preventive supervision and sits alongside two regulations that apply directly.

When a policy document says 6AMLD without a number, ask which one it means before acting on it.

What does Directive (EU) 2018/1673 criminalise?

It sets minimum rules for the definition of the offence and the level of penalty, so that a laundering prosecution does not fail because two member states drew the offence differently. Article 3 covers converting or transferring property known to derive from criminal activity in order to conceal its origin or help an offender evade the consequences, concealing the true nature, source, location or ownership of that property, and acquiring, possessing or using it.

Article 5 requires those offences to be punishable by a maximum term of imprisonment of at least four years. That is a floor on the maximum available in national law, not a sentencing tariff and not a cap.

Article 6 then requires aggravating circumstances where the offence was committed within a criminal organisation, or by an obliged entity in the exercise of its professional activities. A regulated firm is treated more severely than an unregulated one for the same conduct.

Which 22 predicate offences does Article 2(1) list?

The list defines the criminal activity whose proceeds can be laundered. It covers participation in an organised criminal group and racketeering, terrorism, trafficking in human beings and migrant smuggling, sexual exploitation, illicit trafficking in narcotic drugs and psychotropic substances, illicit arms trafficking, and illicit trafficking in stolen goods.

It continues with corruption, fraud, counterfeiting of currency, counterfeiting and piracy of products, environmental crime, murder and grievous bodily injury, kidnapping, illegal restraint and hostage taking, robbery or theft, smuggling, tax crimes relating to direct and indirect taxes, extortion, forgery, piracy, insider dealing and market manipulation, and cybercrime.

Two entries change the practical reach of the offence. Environmental crime brings proceeds from activity such as wildlife trafficking unambiguously into scope, and cybercrime covers ransomware proceeds. Both belong in the typology section of an AML risk assessment, not only in a criminal lawyer's file.

How does the directive make companies criminally liable?

Article 7 requires member states to make legal persons liable for the offences in Article 3 where they are committed for the benefit of the legal person by someone in a leading position, and also where a lack of supervision or control by such a person made the offence possible. The second limb is the one that matters operationally, because it does not require the company to have wanted the outcome.

Article 8 then sets out the measures that must be available against a liable legal person. They include criminal or non-criminal fines, exclusion from entitlement to public benefits or aid, temporary or permanent exclusion from access to public funding, temporary or permanent disqualification from commercial activities, placing under judicial supervision, judicial winding-up, and temporary or permanent closure of establishments used to commit the offence.

None of those measures is imprisonment. Custodial sentences under this directive attach to natural persons under Article 5.

What changes when Regulation (EU) 2024/1624 applies from 10 July 2027?

The preventive rulebook moves from a directive that each member state wrote into its own law to a regulation that applies directly and identically. That removes the divergence a group compliance function currently manages between, for example, German and Irish transpositions of the same article.

Substantive changes arrive with it. Article 80 caps cash payments for goods or services at EUR 10 000 across the Union, whether in a single operation or in linked operations, and member states may keep or set lower national limits. Article 79 bars credit institutions, financial institutions and crypto-asset service providers from keeping anonymous accounts, passbooks, safe-deposit boxes and anonymous crypto-asset accounts.

The obliged entity list also widens. Professional football clubs and football agents come into scope, and for them the regulation applies from 10 July 2029 rather than 10 July 2027.

Which parts of Directive (EU) 2024/1640 bite before 2027?

Article 78 sets a general transposition deadline of 10 July 2027, then carves out three earlier or later dates. Reading only the general deadline is the most common planning error, because the register work starts sooner and the real estate access point lands later.

Article 77 repeals Directive (EU) 2015/849 with effect from 10 July 2027, so the fourth and fifth directives remain the live framework until that date. Firms that source obligations from national transpositions should date-stamp their obligation register accordingly.

What penalties can supervisors impose under the 2024 directive?

Article 55 requires pecuniary sanctions for serious, repeated or systematic breaches of the internal policies, customer due diligence, reporting and record retention chapters of Regulation (EU) 2024/1624, whether committed intentionally or negligently. The maxima are floors that member states must provide for, and national law may go higher.

Article 57 adds periodic penalty payments, which run until the firm complies with an administrative measure and may not run for longer than 12 months. That instrument targets slow remediation rather than the original breach, and it changes how a supervisory finding should be project-managed.

What does AMLA change for a supervised firm?

Regulation (EU) 2024/1620 established the Authority for Anti-Money Laundering and Countering the Financing of Terrorism, seated in Frankfurt am Main. AMLA is scheduled to begin direct supervision of selected obliged entities in 2028, focused on the most significant cross-border financial institutions, while national supervisors keep everyone else.

Three effects reach firms that AMLA will never supervise directly. It writes the regulatory technical standards that give the regulation its operating detail, including the methodology for sanctions and periodic penalty payments. It coordinates national supervisors, which narrows the room for a lenient home-state reading. And it supports financial intelligence units, which affects how cross-border reports are handled.

Watching AMLA's consultations is therefore worthwhile even for a domestic firm, because the technical standards, not the regulation, will settle most implementation questions.

What should a compliance programme do before 10 July 2027?

Start with the obligation register. Every control currently justified by a national transposition of Directive (EU) 2015/849 needs a new citation in Regulation (EU) 2024/1624, and the mapping exercise reveals where a national rule was stricter than the coming EU text, which is where the real change sits.

Then work through the specific deltas: the EUR 10 000 cash limit, the prohibition on anonymous accounts, the widened obliged entity list, and beneficial ownership register access under the earlier 2026 deadline. Screening and enhanced due diligence procedures should be rewritten against article references in the regulation rather than against a national circular that will be superseded.

Two neighbouring regimes are already in force and should be checked in the same pass: the EU Transfer of Funds Regulation, which has applied since 30 December 2024, and the wider FATF Travel Rule position for firms transferring value across borders. The European Commission's AML pages track the package, and our jurisdictions and regulation collection covers the national regimes alongside it.