14/10/2026
AMLR vs AMLD: Regulation Replaces Directive
The old framework was a directive: Directive (EU) 2015/849. A directive binds Member States to reach a result, and each one writes its own law. The result, in practice, was 27 versions of the same rules, with gaps and gold-plating at the edges.
Regulation (EU) 2024/1624 works differently. A regulation applies directly. From 10 July 2027, per its Article 90, the same text applies to every obliged entity in the EU.
Three differences that matter
1. One text. Customer due diligence, beneficial ownership and reporting rules sit in the Regulation itself. Article 89 says that references to Directive 2015/849 are to be read as references to the AMLR and to the new Directive (EU) 2024/1640, with Annex VI mapping old provisions to new.
2. A companion directive remains. The AMLR does not do everything. Supervision and national framework rules are in the 2024 directive, which Member States still have to implement. National supervisors therefore keep a role.
3. A new authority. AMLA, created by Regulation (EU) 2024/1620, writes standards and, according to its own pages, will directly supervise 40 selected cross-border financial entities from 2028. See AMLA and the AMLR.
A concrete case
Take a payment institution in Malta that serves customers in Germany and Spain. Under a directive, its Maltese procedures, the German branch’s local overlay and the Spanish agent’s local rules could each read slightly differently. Under the AMLR the baseline is one text everywhere. Article 8 still deals with notifying cross-border operations and applying national law, so do not assume complete uniformity.
Our view
The headline is harmonisation, but the real change is accountability. A regulation leaves less room to say “our national law did not require that”. The ones who will struggle are firms whose procedures were built to the minimum of one jurisdiction.
What this means for you
Read your current policies against Chapters II and III of the Regulation and list what differs. If you want to compare notes, use our enquiry form to talk to an expert. For the sequence of dates, see the timeline to 2027.
General information, not legal advice.