Who this is for: carriers, MGAs, coverholders and brokers writing EU domiciled risk, holding EU counterparties, or handling euro payments. It sets out what EU sanctions law and the EU anti money laundering framework actually require, with the source for every obligation. It is general information, not legal advice.
Last reviewed 23 August 2026.
“6AMLD” now refers to two different instruments and people use it for both.
Directive (EU) 2018/1673 harmonised the criminal definition of money laundering and was widely called the Sixth Anti Money Laundering Directive when it landed. Directive (EU) 2024/1640, part of the 2024 package, is also called AMLD6 and is the one that matters going forward.
If a document says 6AMLD without a number, check which one it means. This page uses the 2024 numbering.
The EU replaced its directive based AML framework with a package of three instruments. The significance for a firm is that the core rulebook is now a Regulation, which applies directly in every member state without national transposition, rather than a directive that each country implements differently.
| Instrument | What it is | Key date |
|---|---|---|
| Regulation (EU) 2024/1624, the AMLR | The directly applicable single rulebook. Customer due diligence, beneficial ownership, obliged entities. | Applies from 10 July 2027 |
| Directive (EU) 2024/1640, AMLD6 | The national framework: supervision, financial intelligence units, registers. | Transposition by 10 July 2027 |
| Regulation (EU) 2024/1620 | Establishes AMLA, the Authority for Anti Money Laundering and Countering the Financing of Terrorism, based in Frankfurt. | AMLA operational since 1 July 2025 |
One change that looks like drafting and is not. The beneficial ownership threshold moves from more than 25 percent under the previous directives to 25 percent or more under the AMLR. A person holding exactly 25 percent was outside the definition and is now inside it. Any ownership data captured against the old threshold will need re-running.
This is the single most important difference for a firm that has built its screening around the US regime.
OFAC blocks an entity that is owned 50 percent or more in the aggregate by blocked persons. Control alone does not automatically block it.
The EU applies ownership and control as alternative tests. Either one is sufficient.
The ownership limb is possession of 50 percent or more of the proprietary rights of an entity, or a majority interest in it.
The control limb is separate and much broader. The official criteria are non exhaustive and include:
Where a designated person owns or controls an entity, all funds and economic resources of that entity must be frozen, and nothing may be made available to it, because those assets are presumed to be controlled by the designated person.
And the entity will usually not be on the list. The official guidance is explicit that most entities owned or controlled by a designated person are not listed by name, because structures change and new entities are created constantly.
The consequence for underwriting is direct. Screening a corporate insured against the EU Consolidated List will not, on its own, tell you whether that insured is caught. Ownership has to be resolved, and so does control, which is harder because control is not always visible in a shareholding register.
Directive (EU) 2024/1226 harmonised criminal offences and penalties for violating EU restrictive measures. It entered into force on 19 May 2024 with a transposition deadline of 20 May 2025.
What it criminalises. Intentional violations including making funds available to a designated person, failing to freeze assets, enabling entry or transit, conducting prohibited transactions, trading restricted goods or services, and providing prohibited financial services. Article 3(1) also covers circumvention.
Serious negligence is enough for some offences. Article 3(4) provides that conduct committed with serious negligence should also constitute a criminal offence, at least where it relates to items on the EU Common Military List or to dual use items.
The penalties.
| Who | Minimum maximum penalty member states must provide |
|---|---|
| Natural persons | One to five years imprisonment, depending on the offence, under Article 5 |
| Legal persons | Fines of 1 to 5 percent of total worldwide turnover, or EUR 8,000,000 to EUR 40,000,000, depending on the offence and the calculation method, under Articles 6 and 7 |
Transposition is incomplete and the Commission is chasing it. On 24 July 2025 the European Commission opened infringement procedures against 18 member states for failing to fully transpose the directive by the deadline: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, France, Germany, Greece, Hungary, Ireland, Italy, Malta, Poland, Portugal, Romania, Slovenia and Spain.
That matters practically. The penalty a firm faces for the same conduct currently differs by member state, and the position is changing as each state transposes. A group writing risk across several EU countries cannot assume one answer.
| Obligation | What it requires in practice |
|---|---|
| Screen against the EU Consolidated List | Necessary and nowhere near sufficient on its own, because owned and controlled entities are usually not listed. |
| Resolve ownership to 50 percent or more | Aggregated, direct and indirect, through the structure rather than at the first layer. |
| Resolve control separately | The harder half. Board appointment rights, shareholder agreements, dominant influence and guarantees do not appear in a name screen. |
| Re-run beneficial ownership at 25 percent or more | The AMLR threshold change captures holdings that were previously outside the definition. |
| Treat the EU and US tests as different | A control based EU exposure will pass an OFAC 50 percent test cleanly. Running one test for both regimes leaves a gap. |
| Track transposition by member state | Criminal exposure under Directive 2024/1226 is not yet uniform across the Union. |
| Evidence the decision | Serious negligence is enough for some offences. A disposal with no recorded reasoning is difficult to defend against that standard. |
They are different instruments and both have been called the sixth directive. Directive (EU) 2018/1673 harmonised the criminal definition of money laundering. Directive (EU) 2024/1640 is part of the 2024 EU AML package and sets the national framework for supervision, financial intelligence units and registers, with a transposition deadline of 10 July 2027. When a document says 6AMLD without a number, check which one it means.
Regulation (EU) 2024/1624, the AMLR, applies from 10 July 2027. Directive (EU) 2024/1640 must be transposed by the same date. AMLA, the Authority for Anti Money Laundering and Countering the Financing of Terrorism, was established by Regulation (EU) 2024/1620, is based in Frankfurt and has been operational since 1 July 2025.
Yes. It moves from more than 25 percent under the earlier directives to 25 percent or more under the AMLR. A person holding exactly 25 percent was previously outside the definition and is now inside it, so ownership data captured under the old threshold needs re-running.
No, and this is the difference that catches firms out. OFAC blocks an entity owned 50 percent or more in the aggregate by blocked persons, and control alone does not automatically block it. The EU applies ownership and control as alternative tests, so either is sufficient. An entity a designated person controls without owning half of it is caught in the EU and may not be under the US rule.
The criteria are non exhaustive and include the right or power to appoint or remove a majority of the leadership bodies, controlling a majority of voting rights through a shareholder agreement, the right or power to exercise a dominant influence, the right to use all or part of the entity’s assets, managing operations on a unified basis with consolidated accounts, and sharing jointly and severally or guaranteeing the entity’s financial liabilities.
Usually not. Official guidance states that most entities owned or controlled by a designated person are not listed by name, because ownership structures change and new entities are created regularly. Screening against the published list alone will not identify them. Ownership and control have to be resolved separately.
Yes. Directive (EU) 2024/1226 harmonised criminal offences and penalties across the Union, with a transposition deadline of 20 May 2025. Member states must provide imprisonment of one to five years for natural persons and fines for legal persons of 1 to 5 percent of total worldwide turnover or EUR 8,000,000 to EUR 40,000,000, depending on the offence. Serious negligence is sufficient for some offences under Article 3(4), at least where the violation relates to items on the EU Common Military List or to dual use items.
No. On 24 July 2025 the European Commission opened infringement procedures against 18 member states for failing to fully transpose Directive (EU) 2024/1226 by the 20 May 2025 deadline. Penalties for the same conduct currently differ by member state and the position changes as each state transposes.
Global RADAR screens against the EU Consolidated List alongside more than 1,400 sanctions and watchlists on a daily update cycle, and resolves ultimate beneficial ownership so that entities caught by ownership rather than by listing are surfaced. Every disposal carries a reason code, a rationale and a confidence score, and the record is exportable and reproducible, which is what a serious negligence standard actually demands.
One thing we will say plainly: the control limb of the EU test is not fully solvable by data alone. Board appointment rights, dominant influence and guarantee arrangements are not always in any register. The platform surfaces what is discoverable and escalates the rest rather than clearing it, which is the correct behaviour when the alternative is a criminal standard met by serious negligence.
Read the full alert clearing methodology and model governance, or compare the US position under OFAC.
