AMLR 2027: what changes for non-banking professions
On 10 July 2027, the European anti-money-laundering regulation (AMLR) will become directly applicable. Here is what wealth and real estate professionals should anticipate.
In 2024 the European Union adopted a new anti-money-laundering package. Its centrepiece, the AMLR regulation (EU) 2024/1624, will be directly applicable on 10 July 2027 — without national transposition, hence with an immediate and harmonised effect across all Member States.
Why a regulation is a game-changer
Unlike a directive, a regulation applies as it stands. Due diligence obligations, the definition of the beneficial owner and the risk-based approach will be standardised at European level. For non-banking professions, the expected effect is a raising of the level of requirements and an increased formalisation of process documentation.
Three concrete points to watch
The beneficial owner
The reference threshold remains around 25% of capital or voting rights, but the harmonised European definition and the identification arrangements are being clarified. Anticipate a stronger traceability requirement when reconstructing ownership chains.
Due diligence, more formalised
The risk-based approach, risk scoring and periodic review will have to be documented in a more structured way. "Having a procedure" will not be enough: you will need to be able to demonstrate that it is applied, file by file.
A European supervisor: the AMLA
A new European authority, the AMLA (headquartered in Frankfurt), will coordinate supervision. It will directly supervise a small number of high-risk financial entities; the non-financial professions — estate agents, notaries, chartered accountants, wealth managers — will remain supervised by their national authorities, with the AMLA exercising indirect supervision.
What to do before 2027?
- Map your risks in writing and keep the mapping up to date.
- Equip your operational due diligence so that every file leaves a timestamped trail.
- Train your teams and appoint an AML/CFT officer.
- Test your ability to reconstruct a complete file in the event of an inspection.
Vigilae was designed for this transition: the AI prepares and structures, the deterministic engine scores and screens, and the professional keeps the decision. The outcome is a presentable evidence file — with no promise of "guaranteed compliance," which does not exist.
Informative article, current as of June 2026, not constituting legal advice. The dates and arrangements for application are governed by European legislation and the competent authorities.
Frequently asked questions
When does the AMLR apply?
The AMLR regulation (EU) 2024/1624 is directly applicable as from 10 July 2027.
Will the AMLA supervise me directly?
Most probably not if you practise a non-financial profession: you will remain supervised by your national authority, with the AMLA exercising indirect supervision.
Is the beneficial ownership threshold changing?
The threshold remains around 25%, but the harmonised European definition and the identification arrangements are being clarified under the AMLR.
Where does your AML/CFT compliance stand?
The free Vigilae audit gives you a score out of 100 and your 3 priority gaps in 2 minutes.
Start my free audit