The European Union’s Anti-Money Laundering Package (AML Package) presents a paradigm shift in anti-money laundering supervision for payment service providers. To help you maintain an overview and stay up to date, we have updated our blog post to reflect all recent developments and summarised the key provisions for you in a visual chart.
All Set and Soon Mandatory: The EU AML Package
The European Union aims to step up its fight against money laundering and terrorist financing. To that end, it has adopted a comprehensive package of measures that primarily targets the European financial sector. The AML Package consists of the 6th Anti-Money Laundering Directive (AMLD6), the Anti-Money Laundering Regulation (AMLR), and the Regulation establishing the new European Anti-Money Laundering Authority AMLA (AMLAR). It is supplemented by the recast Funds Transfer Regulation (FTR).
The AMLD6 must be transposed into national law by the EU Member States by 10 July 2027. At that point, the previous AMLD4—amended in the meantime by AMLD5—will be repealed. The AMLR does not require transposition and will become directly applicable in all Member States as of 10 July 2027. Certain provisions of the AMLAR have applied since 1 July 2025. The revised FTR has been in effect since 30 December 2024.
New Obligations for Authorities and Payment Service Providers
Member States must now establish centralised registers or digital query systems to identify all natural or legal persons who hold or control IBAN-linked accounts or safe deposit boxes at a credit or financial institution. The threshold for carrying out Customer Due Diligence (CDD) in the case of occasional transactions is lowered from EUR 15,000 to EUR 10,000, and there is a mandatory requirement to keep customer information up to date.
In addition, the German legislature may in future require payment service providers operating in a Member State through agents or other infrastructure to appoint a central contact point responsible for coordinating compliance with anti-money laundering regulations. Regulatory requirements for the outsourcing of tasks will also be tightened.
Implementing Standards, Guidelines and Guidance Notes
Financial service providers must monitor not only the European base legislation and national law: the European Commission has issued numerous delegated acts in the form of Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) that define the statutory AML requirements in binding detail.
Moreover, payment service providers should stay up to date with guidelines, communications and guidance notes from European supervisory authorities and BaFin, which offer practical support in interpreting and applying the law.
Stay on Top – with Our Visual Overviews
To help you maintain an overview, we have compiled the most important legal sources and interpretive guidance in an interactive chart available for download. It provides a clear summary of all relevant AML requirements – including direct links to the original legal texts. This way, you always have the key obligations at your fingertips.
For a full picture, we have also created visual guides for legal sources relevant to payment services supervision and IT supervision law.
This article was last updated on 15 July 2025.
