AMLA in Frankfurt: the 2027 EU anti-money-laundering reform
Europe is rebuilding its anti-money-laundering regime. From 10 July 2027 a single EU Regulation replaces much of the German Anti-Money-Laundering Act, and the new European supervisor, the AMLA, is based in Frankfurt. The circle of obliged entities grows rather than shrinks, and the firms that fall outside it are still not free of criminal exposure.
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At the centre of the EU anti-money-laundering package is the Anti-Money-Laundering Regulation, Regulation (EU) 2024/1624 (AMLR), which applies directly in every member state from 10 July 2027. Because a regulation does not need to be transposed into national law, it takes effect without a German implementing act. The German Anti-Money-Laundering Act (Geldwäschegesetz, GwG), the statute that compliance teams have worked to for years, is replaced in large part. The aim is one rulebook with the same rules from Lisbon to Riga, less room for national interpretation and fewer special routes.
The package also creates a new authority: the Anti-Money-Laundering Authority (AMLA), the European anti-money-laundering supervisor, with its seat in Frankfurt am Main. It took on central tasks in 2026, is consulting on the first technical standards, and is preparing to supervise the highest-risk obliged entities directly from 2028. For companies in the Rhine-Main region this is more than a footnote: the European supervisor is being built here, with the staff, the institutional culture and the early precedents that come with it.
Who AMLA will supervise directly from 2028
Alongside its coordinating role, AMLA takes on the direct supervision of a limited number of particularly high-risk, cross-border financial institutions from 2028. Whether an institution falls under direct supervision turns on thresholds for cross-border activity and risk. On the consultation draft, the criteria are activity in at least six member states, a transaction volume of EUR 50 million and around 20,000 customers. The technical standards that steer this selection are in consultation, so the final figures are what will count.
Directly supervised institutions deal with AMLA itself: its inspections, its requests for information and its sanctioning powers. That is a different depth of intervention from national supervision alone.
An EU-wide cash cap of EUR 10,000
The most tangible change is the cash cap. From 10 July 2027 cash payments of EUR 10,000 or more for the commercial purchase of goods or services are prohibited across the EU. A customer-identification duty already applies from EUR 3,000 for occasional transactions. This reaches whole business models, from the trade in vehicles, watches, art and precious metals to parts of construction and hospitality. Anyone still working with high cash volumes should begin the changeover now, not in 2027.
Who becomes an obliged entity
The direction is clear: the circle of obliged entities widens. It expressly includes crypto-asset service providers, estate agents and dealers in high-value goods, and from 2029 even professional football clubs. Businesses that have never seen themselves as part of the anti-money-laundering regime should check now whether they will be from 2027.
Dropping out does not mean you are clear
Some businesses will fall outside the supervisory duties. That does not end criminal exposure. Money laundering under section 261 of the German Criminal Code (Strafgesetzbuch, StGB) is drafted as an all-crime offence and can be committed recklessly (leichtfertig). A company with no remaining supervisory obligations can still face a criminal allegation. The supervisory perimeter and the criminal perimeter are not the same line.
What to do before 2027 and 2028
Start with a sober self-assessment: does your institution approach the thresholds, or does it sit clearly below them? Those who come close should mirror their due-diligence, reporting and documentation processes against the emerging standards early. This is a matter of months, not a switch to be flipped on the deadline. The consultation is also a rare design window: those who will be affected can still comment on the rules by which they will later be examined.
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AMLA and the 2027 reform, briefly explained.
Does the AMLR replace the German Anti-Money-Laundering Act?
In large part, yes. The Anti-Money-Laundering Regulation, Regulation (EU) 2024/1624, applies directly from 10 July 2027 and replaces much of the German Anti-Money-Laundering Act (GwG). Because it is a regulation, it takes effect without a German implementing act.
Which businesses will AMLA supervise directly?
From 2028 AMLA supervises a limited number of high-risk, cross-border institutions directly. On the consultation draft the thresholds are activity in at least six member states, a transaction volume of EUR 50 million and around 20,000 customers. The final technical standards will be decisive.
If our company is no longer an obliged entity, are we free of money-laundering risk?
No. Money laundering under section 261 StGB is an all-crime offence and can be committed recklessly. Losing supervisory duties does not remove criminal exposure. The supervisory perimeter and the criminal perimeter are separate.
This page gives a general overview and does not replace advice on the individual case. Legal position: 2026; selection thresholds refer to the consultation draft of the technical standards.
Related pages.
Read more on our defence work in money laundering and capital-markets criminal law and on internal investigations.
Where do you stand under the 2027 rules?
We assess whether and how close you come to direct AMLA supervision, and align your processes with the emerging standards.
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