AMLR 2027: what the new EU AML rulebook means for obliged entities

With Regulation (EU) 2024/1624, known as the AMLR, the EU replaces a large part of the previously nationally implemented anti-money laundering rules with a directly applicable rulebook. It applies in all member states from 10 July 2027, without first having to be transposed into national law. For obliged entities in Austria, such as lawyers, notaries and accountants, this changes the legal basis of their due-diligence duties.

Why a regulation instead of a directive

EU anti-money laundering directives had to be transposed by each member state individually. That led to differences in detail, interpretation and professional rules. A regulation, by contrast, applies directly and uniformly. In Austria, AML law for lawyers, notaries and accountants is currently set out in the respective professional statutes. National rules will mainly keep their importance where the EU rules leave room for manoeuvre, for example on supervision and procedure.

What changes in practice

• Uniform due diligence: Risk assessment, identification of clients and beneficial owners, and ongoing monitoring follow the same rulebook across the EU.
• Cash limit: Anyone trading in goods or providing services generally may neither accept nor make cash payments above EUR 10,000. Member states may set lower limits.
• New EU authority: The Anti-Money Laundering Authority (AMLA), based in Frankfurt, coordinates national supervisors and, from 2028, directly supervises selected cross-border financial institutions. For most obliged entities, national supervision remains responsible.
• Technical standards: Many details, such as customer due diligence, will be specified in technical standards drawn up by the AMLA. These are being prepared now and should be monitored closely.

What you can do now

1. Take stock: Check which risk assessment, internal policies and processes exist and whether they are fully documented.
2. Identify gaps: Compare your procedures with the new requirements as soon as your chamber or supervisor publishes guidance.
3. Consolidate documentation: When risk assessment, client checks and logs live in one place, new requirements are quicker to implement.
4. Train your team: Obligations only change in practice when everyone involved knows them. Schedule training well before the deadline.

Conclusion

The AMLR brings a single rulebook, but not a fresh start. Law firms and notaries that put their risk assessment and documentation in order now will only have to adjust details in 2027. Those who start shortly before the deadline risk time pressure and gaps.

Source: Regulation (EU) 2024/1624 on EUR-Lex