The EU AML package and its dates
The EU AML package is three legal acts with three different start dates, and the dates are what a compliance plan runs on. One regulation replaces most of what the Geldwäschegesetz says today, one directive tells Germany what to put in national law, and one builds the supervisor. AMLA in Frankfurt covers the authority; the subject here is the legislation.
The three instruments
Regulation (EU) 2024/1624, the AMLR, is the single rulebook: who is an obliged entity, what customer due diligence means, what internal policies and controls are required, and what has to be reported. As a regulation it applies directly, without a German transposition act.
Directive (EU) 2024/1640, AMLD6, covers what member states have to build: supervisory powers, the FIU, the beneficial ownership registers, the register of bank accounts, and access to real estate information. Germany transposes it into national law. Regulation (EU) 2024/1620 establishes AMLA and sets its supervisory powers.
The dates that matter
The AMLA regulation came first, applying from July 2025, which is why the authority already exists and is already in Frankfurt. Most of the AMLR applies from July 10, 2027, and that is the date a German institution's own obligations change.
AMLD6 has to be transposed by July 10, 2027 as well, with several provisions earlier: access to beneficial ownership information was due by July 10, 2025, the further development of the beneficial ownership registers by July 10, 2026, and the single access point for real estate information by July 10, 2029. A plan built on one date for the whole package misses the register work, which is the part that runs first.
The 10,000 euro cash limit
The AMLR introduces an EU-wide limit on cash payments: 10,000 euros for a payment in cash in the course of a trade or business, with member states free to set a lower one. Germany has no general cash limit today, which makes this a change in substance and not only in form.
Below the limit the obligation is identification and not prohibition. A person dealing in goods has to identify the customer for an occasional cash transaction from 3,000 euros, so the German regime of thresholds for Güterhändler changes shape as well. The limit applies from the same July 10, 2027 date as the rest of the AMLR.
Crypto-asset service providers fully in scope
The AMLR makes crypto-asset service providers obliged entities with the full set of duties, not a special regime at the edge. Due diligence applies from the first transaction in defined cases, transfers carry the information requirements of the travel rule, and relationships with self-hosted wallets are subject to additional measures.
For a provider holding a MiCA license this stacks on top of the market rules it already follows, which the crypto-asset service provider license covers. The travel rule in crypto covers the transfer information duty and AML in crypto assets the wider sector picture.
What happens to the Geldwäschegesetz
Most of the GwG's substantive content is replaced by the AMLR, because a regulation leaves no room for a parallel national rule on the same subject. The duties German practitioners know by their section numbers, section 10 on due diligence and section 43 on reporting, will be found in the regulation instead.
What stays in German law is what AMLD6 assigns to member states: the supervisory structure and BaFin's powers, the FIU and where it sits, the Transparenzregister, and the sanctions for breaches. The German act will therefore be rewritten and not repealed, and the practical risk in the transition is a control documented against a section number that no longer exists.
Beneficial ownership: the threshold and the register access
The AMLR writes the beneficial ownership threshold into EU law at 25 percent of shares or voting rights, with the ownership and the control test both set out, and it addresses multi-layered structures where the chain has to be followed through.
Register access changed because of a court ruling. In November 2022 the Court of Justice of the European Union held in joined cases C-37/20 and C-601/20 that the general public's access to beneficial ownership information, as provided by the earlier directive, was invalid as a disproportionate interference with the rights to private life and data protection. AMLD6 rebuilds access on that basis: authorities and obliged entities keep it, and others need a legitimate interest.
What a German institution does before 2027
Three pieces of work come before the date. Mapping: each existing control is traced to the provision that requires it, so the ones resting on the GwG can be re-derived from the AMLR. Gap analysis on the genuinely new parts, which for most institutions means the harmonized due diligence rules and the tighter beneficial ownership expectations.
And the technical standards. AMLA writes the detail underneath the regulation, and those standards arrive between now and the application date, so a control built to the regulation's text alone may still need adjusting. KYC in Germany and AML in Germany cover the duties as they stand today.
What is the EU AML package?
The EU AML package is three legal acts adopted in 2024: Regulation (EU) 2024/1624, the AMLR, which is the directly applicable single rulebook for obliged entities; Directive (EU) 2024/1640, AMLD6, which tells member states what supervisory structures and registers to build; and Regulation (EU) 2024/1620, which establishes AMLA, the EU anti-money-laundering authority seated in Frankfurt.
When does the EU AML package apply?
The AMLA regulation applies from July 2025. Most of the AMLR applies from July 10, 2027, which is the date an institution's own obligations change. AMLD6 has to be transposed by July 10, 2027, with earlier deadlines for parts of the beneficial ownership work in 2025 and 2026, and a later one in 2029 for the single access point for real estate information.
Does the EU AML package replace the GwG?
In substance, largely yes. The AMLR takes over the due diligence, internal controls and reporting duties that the GwG sets out today, because a directly applicable regulation displaces parallel national rules on the same subject. German law keeps what AMLD6 leaves to member states, including the supervisory powers, the FIU, the Transparenzregister and the penalty regime, so the German act is rewritten around a smaller scope.
Will cash payments over 10,000 euros be banned in Germany?
From July 10, 2027 a cash payment above 10,000 euros in the course of a trade or business is prohibited under the AMLR, and member states may set a lower limit. Germany has no general limit today, only identification duties from certain amounts, so this is a new restriction and not a tightening of an existing one. Payments between private individuals outside a trade or business are not covered by that limit.
The EU AML package and Finance Loop
Finance Loop is the meeting place for the compliance teams reading these three texts and rebuilding their controls around them. Finance Loop events bring money laundering officers and legal counsel together with the supervisors in Frankfurt who will apply the same rulebook.
Finance Loop is a professional network and has the goal of driving the adoption of emerging technologies in finance, such as AI, tokenization, stablecoins, and DeFi. Finance Loop helps its members build skills and personal networks in these fields: Investment & Digital Assets, Payments & Digital Money, Digital Infrastructure & Sovereignty, and Risk & Compliance.