AMLR vs AMLD6 vs national law: what is the difference?
Three EU texts and a national law that will largely disappear: the confusion is understandable. This page compares them on who they bind, what they regulate and what changes on 10 July 2027, with the Dutch Wwft and the German GwG as examples of national law.
Who each text binds
The quickest way to tell them apart:
- AMLR (Regulation 2024/1624): binds obliged entities directly. Customer due diligence, beneficial ownership, internal policies, reporting, record keeping, cash limit.
- AMLD6 (Directive 2024/1640): binds Member States. Supervisors, FIUs, beneficial ownership registers, bank account registers, sanctions, cooperation. Transposed into national law.
- AMLAR (Regulation 2024/1620): creates AMLA, gives it the mandate to draft RTS, ITS and Guidelines, and the power to supervise selected institutions directly.
- National AML law (Wwft, GwG, and others): today the source of the obligations; from 10 July 2027 reduced to what AMLD6 requires plus the options the AMLR leaves to Member States.
What changes compared with national law
The AMLR harmonises what used to differ per country: one beneficial ownership threshold of 25 percent with control through other means, a fixed set of identity data and verification methods, enhanced due diligence for wealth above 50 million euro, suspicion-based reporting on an EU template, a compliance manager at management-body level, hard limits on outsourcing, and a cash limit of 10,000 euro. National indicator lists, national simplified-due-diligence categories and national guidance are superseded by AMLA Guidelines.
What stays national
Supervision and enforcement (who inspects you, what fines look like), the FIU and its reporting channel (goAML in the Netherlands), the registers, the option of a lower cash limit (3,000 euro in the Netherlands), extra obliged entities a Member State adds, and tax and company law that determine who a beneficial owner is in practice.
How to run the comparison for your own policies
Map every policy article to its AMLR article, note where an AMLA RTS or Guideline will add detail, and mark what falls back to national law. The AMLR Monitor workspace does this per framework block with a gap note per block, an AI impact assessment for your organisation and country-specific points for every country you operate in.
Frequently asked questions
Does the AMLR replace the Wwft?
Largely. From 10 July 2027 the obligations of obliged entities come from the AMLR. The Wwft, or its successor implementing AMLD6, keeps supervision, the FIU, registers, sanctions and the national options such as the 3,000 euro cash limit.
Does the AMLR replace the German GwG?
In the same way: the GwG obligations covered by the AMLR fall away on 10 July 2027; the parts implementing AMLD6 (supervision, Transparenzregister, FIU) remain in national law.
Is AMLD6 the same as the 2018 directive on criminalising money laundering?
No. Directive (EU) 2018/1673 is sometimes called "6AMLD" too. In the 2024 package, AMLD6 means Directive (EU) 2024/1640 on the mechanisms Member States must put in place.
Do AMLA Guidelines bind me?
On a comply-or-explain basis: supervisors and obliged entities must make every effort to comply and explain where they do not. RTS and ITS, once adopted by the Commission, are binding law.
See the status of every AMLR rule, then what it means for you
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