Every obliged entity under Art. 3 of the EU Anti-Money Laundering Regulation, grouped by sector. For each type: what the AMLR means, from when it applies, and where the work usually sits. Pick your type to start an analysis for your organisation.
The classic gatekeepers: credit and financial institutions in the sense of Art. 2 AMLR. The whole regulation applies to them from 10 July 2027, and the largest cross-border groups can be selected for direct AMLA supervision from 2028.
Supervision: National prudential and conduct supervisors (in the Netherlands: DNB and, for investment firms, fund managers and crowdfunding, the AFM); AMLA directly for around 40 selected cross-border institutions.
Retail and commercial banks, savings banks, mortgage banks.
The whole AMLR applies; correspondent banking and group-wide rules weigh most.
Consumer-credit providers, leasing companies, factoring companies, currency exchange offices.
The whole AMLR applies to the financial activities; the risk assessment decides how deep due diligence goes.
Mortgage lenders, credit intermediaries, buy-now-pay-later providers.
The whole AMLR applies; source of funds and beneficial ownership of borrowers are the focus.
Payment service providers, acquirers, e-money issuers, money remitters.
The whole AMLR plus the Transfer of Funds Regulation; transaction monitoring and agent oversight weigh most.
Brokers, asset managers, AIFMs, UCITS management companies.
The whole AMLR applies; investor and beneficial-owner identification and high-net-worth EDD weigh most.
Life insurers, insurance intermediaries selling life or investment products.
Applies to life and investment-related insurance, not to non-life business; beneficiary checks at pay-out are specific to this sector.
Pension administrators, premium pension institutions offering individual products.
Mandatory collective schemes are largely out of scope; individual or transferable products bring the AMLR in.
Loan- and investment-based crowdfunding platforms.
New under the AMLR: due diligence on project owners and investors and monitoring of the funds flow.
Exchanges, custodial wallet providers, crypto brokers.
The whole AMLR plus the travel rule and self-hosted-address measures (Art. 37-38); fully new at EU level.
Accountants, tax advisers, lawyers, notaries, trust and company service providers and external compliance advisers. The AMLR applies when they carry out or assist with the transactions listed in Art. 3 (company formation, real-estate deals, managing client money, tax advice, and so on).
Supervision: National sector supervisors and self-regulatory bodies (in the Netherlands: the BFT for notaries, lawyers, accountants and tax advisers; DNB for trust offices). Sanctioning powers stay national under AMLD6.
Trust offices, company formation agents, registered-office and nominee providers.
The whole AMLR applies; beneficial ownership and nominee arrangements weigh most.
Audit firms, accounting and bookkeeping practices.
Applies to the professional services listed in Art. 3; client acceptance per engagement and reporting duties weigh most.
Tax advisory firms, independent tax advisers.
Applies to tax advice and related structuring work; beneficial-ownership checks on client structures weigh most.
Notaries, law firms, legal service providers.
Applies only when assisting with the listed transactions; legal professional privilege is preserved for litigation and legal advice.
KYC outsourcing providers, compliance consultancies performing due diligence.
In scope when performing due diligence or related services; outsourcing and third-party-reliance rules (Art. 18, 48) shape the work.
Estate agents, intermediaries and valuers when involved in a transaction. Customer due diligence applies to buyer and seller for every transaction, letting included above the rent threshold.
Supervision: National supervisor for the non-financial sector (in the Netherlands: Bureau Toezicht Wwft of the Belastingdienst).
Real-estate agencies, property intermediaries, valuers acting in a transaction.
Due diligence on buyer and seller for every transaction, and on tenants above the rent threshold.
Dealers in high-value goods and auction houses are obliged entities. Every trader in goods or services is bound by the EU cash limit of 10,000 euro (Member States may go lower; the Netherlands has 3,000 euro).
Supervision: National supervisor for the non-financial sector (in the Netherlands: Bureau Toezicht Wwft of the Belastingdienst).
Jewellers, art dealers, car and boat dealers, dealers in precious metals.
In scope for the listed goods and above the transaction thresholds; the cash limit applies to every trader.
Art and antiques auction houses, online auction platforms.
In scope for high-value lots and above the thresholds; buyer and consignor due diligence.
Gambling operators (with some national exemptions) and, from 10 July 2029, professional football clubs and agents.
Supervision: National sector regulators (in the Netherlands: the Kansspelautoriteit for gambling).
Casinos, online gambling operators, betting shops, lotteries where not exempted.
Applies on collection of winnings, wagering of a stake or both, above the thresholds; player identification and monitoring weigh most.
Professional football clubs, football agents.
From 10 July 2029: transactions with investors, sponsors, agents and player transfers.
Any activity in Art. 3 not listed above.
Check Art. 3 AMLR for the activity; the framework blocks apply according to the risk assessment.
The Netherlands: the Wwft is replaced by the AMLR on 10 July 2027; the national cash limit stays at 3,000 euro; DNB, AFM, BFT, Bureau Toezicht Wwft and the Kansspelautoriteit keep supervising their sectors under AMLD6.
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