Although the Sixth Anti-Money Laundering Directive (Directive (EU) 2024/1640) (6AMLD) does not apply until July 2027, firms should already be assessing how the new framework could affect their governance, policies and compliance arrangements. While firms wait for the technical standards to be finalised, they should use this time to assess the likely impact of the new framework and begin planning for the changes that are already clear. Alongside the Anti-Money Laundering Regulation (AMLR) and the Anti-Money Laundering Authority (AMLA), 6AMLD forms part of the EU’s new AML framework and introduces changes to governance, beneficial ownership, information sharing and cross-border cooperation. In this blog, we explain what 6AMLD means in practice and how firms should prepare.
What are the key changes under 6AMLD?
- Beneficial ownership transparency: refined rules on beneficial ownership registers for companies, trusts and similar legal arrangements, including access for those with a legitimate interest and interconnection of national registers at EU level.
- Expanded scope: broadens the scope of centralised bank and payment account registries so that they no longer cover only traditional accounts. In particular, Member States must include securities accounts and cryptoasset accounts or wallets held with service providers in their centralised identification systems.
- Enhanced cooperation: greater emphasis is placed on information sharing among Financial Intelligence Units (FIUs), supervisory authorities, and EU bodies such as AMLA, Europol and Eurojust.
- Risk-based approach: embeds a more formal risk-based approach by requiring regular, systematic money laundering and terrorist financing (ML/TF) risk assessments at both EU and national levels. These supranational and national risk assessments must then feed into how Member States structure their regimes and how supervisors expect firms to calibrate controls, including customer due diligence, monitoring and reporting.
- Senior management checks: tightens expectations around the integrity of those who ultimately run or control obliged entities. Supervisors will be required to verify that senior managers and beneficial owners of obliged entities are of good repute and act with honesty and integrity. This is a supervisory obligation rather than a direct firm requirement, but firms should expect closer scrutiny of the fitness and propriety of those who run or control them.
What firms should be considering now
As firms begin planning for the EU’s new AML framework, there is a natural tendency to focus on the directly applicable requirements under AMLR. However, 6AMLD is an important part of the wider package and will shape how the framework is implemented and supervised across Member States.
Although many of the detailed requirements are still to be finalised through national transposition and supporting measures, firms operating across multiple EU jurisdictions should consider the reforms as a single programme rather than a series of separate initiatives.
For example, a financial institution operating across several EU jurisdictions may review its beneficial ownership processes while separately planning for changes to cross-border information sharing. Taking a joined-up approach can help avoid duplicated effort, support consistent governance and build a more coherent compliance framework ahead of the July 2027 implementation deadline.
What are the key implementation dates for 6AMLD?
Directive (EU) 2024/1640 was adopted in May 2024 and published in the Official Journal in June 2024. Member States must transpose 6AMLD into national law by 10 July 2027, at which point the current 4AMLD framework, as amended by 5AMLD, will be repealed and replaced by the new regime.
Some elements take effect earlier, comprehensive access to beneficial ownership information for legal entities, trusts and similar arrangements must be ensured already by 10 July 2025. In practice, firms should work backwards from the 10 July 2027 application date to ensure that policy, systems and control changes are designed, implemented, tested and embedded during 2026–2027, in parallel with the go-live of AMLA and the AML Regulation.
How should firms prepare for 6AMLD?
Firms should focus on:
- Reviewing and updating AML policies
- Align your policies and business-wide risk assessment with the harmonised preventive requirements of the AMLR and with the EU and national risk assessments the new framework feeds into supervisory expectations.
- Incorporate new requirements for beneficial ownership and cryptoasset transparency.
- Preparing for cross-border cooperation
- Ensure you can respond promptly to information requests from your national FIU and supervisor, whose cross-border cooperation will increase under the new regime.
- Maintain accurate beneficial ownership data and ensure accessibility for competent authorities.
- Investing in technology
- Keep the beneficial ownership and entity data you hold accurate and machine-readable, so it is ready to feed the interconnected registers and account identification systems that Member States are building.
- Implement tools for real-time monitoring and suspicious transaction reporting.
- Training staff
- Educate teams on the obligations that will apply to your firm under the AMLR, including expanded beneficial ownership and cryptoasset transparency.
- Establishing governance and accountability
- Establish clear accountability frameworks for senior executives.
- Document compliance oversight and decision-making processes.
6AMLD marks a significant evolution in the EU’s AML/CFT regime. Firms should act now to review policies, upgrade systems, and train staff to ensure readiness well before the 2027 deadline.
What good looks like
Strong 6AMLD preparation typically includes:
✔ Updated business-wide risk assessment.
✔ Beneficial ownership data reviewed.
✔ Senior management governance documented.
✔ Technology roadmap agreed.
How fscom can help
fscom Compliance Maturity Specialists™ help firms turn 6AMLD’s requirements into practical, embedded controls. We support policy and risk assessment reviews against the new harmonised preventive obligations, strengthen beneficial ownership data and cross-border processes, and help design senior manager due diligence and governance frameworks that meet the new expectations.
We also help clients prepare systems and monitoring capabilities for interconnected registers and expanded account registries, including cryptoasset accounts and wallets.
Whether you are assessing your current framework or preparing for implementation, fscom can help you identify gaps, prioritise remediation and build compliance maturity ahead of July 2027.
This post contains a general summary of advice and is not a complete or definitive statement of the law. Specific advice should be obtained where appropriate.
