14/10/2026
What the AMLR Contains That Procedures Often Miss
We are not going to claim every item below is new. Some existed in national law, some in guidance, some not at all. What we can say is that each is in Regulation (EU) 2024/1624, and that old procedure manuals often do not mention it. Treat this as a checklist, not a verdict.
Scope: who is an obliged entity
Article 3 lists the categories. It includes crowdfunding service providers, investment migration operators, non-financial mixed activity holding companies, traders in cultural goods (for transactions of at least EUR 10,000), and, with a later start of 10 July 2029, football agents and professional clubs. If you advise a client in one of those categories, they may have an AML programme to build.
A full chapter on beneficial ownership
Chapter IV (Articles 51 to 68) sets how to determine beneficial owners through ownership interest, control, or both, and separate rules for express trusts, discretionary trusts, collective investment undertakings and nominees. Procedures that say “25% or more” and stop are probably too thin. Read Articles 52 to 54 before deciding.
Virtual IBANs
Article 22(3) obliges credit and financial institutions to obtain information on the persons using virtual IBANs they issue, and to produce it within five working days. If you issue them, this belongs in your product controls.
Crypto-asset services
Articles 37 and 40 deal with correspondent relationships for crypto-asset service providers and with self-hosted addresses. Article 79 bars crypto-asset service providers from keeping anonymous accounts, including accounts that make tracing harder through anonymity-enhancing coins.
Cash and bearer instruments
Article 80 caps cash payments for goods and services at EUR 10,000, and Member States may set lower limits. Article 79 bans issuing bearer shares, except for companies with listed or intermediated securities, and gives existing ones until 10 July 2029 to be converted, immobilised or deposited. Unconverted shares are cancelled from 10 July 2030.
Group-wide duties
Article 16 puts group-wide obligations on the parent undertaking, defined in Article 2(1)(42).
Our view
If we had to pick one item for most of our clients, it would be the beneficial ownership chapter. It rewards doing the structural analysis properly and punishes the screenshot of a register.
What this means for you
Tick through the headings above against your policy manual. For anything you cannot tick, talk to us: use the enquiry form to schedule a no-obligation call. Also see AMLR vs AMLD and our article-by-article guide.
General information, not legal advice.