EU anti-money laundering law used to be mainly directive law: Brussels set the framework, each member state transposed it its own way. The result was 27 different rulebooks. With the AMLR, Regulation (EU) 2024/1624, the core obligations become directly applicable law — a single rulebook.
Date of application
The Regulation essentially applies from 10 July 2027. It forms a package with the regulation establishing AMLA and the sixth Anti-Money Laundering Directive, which deals with registers and national authorities among other things. Individual provisions apply on a staggered timetable.
What it governs
The AMLR defines who is an obliged entity, which customer due diligence duties apply, when simplified and when enhanced due diligence apply, how to deal with politically exposed persons, which internal controls are needed and how to determine beneficial owners. It also introduces an EU-wide limit of EUR 10,000 for cash payments in trade.
Beneficial owners
Ownership is assumed from a holding of 25 percent or more; control can also exist by other means. The Regulation contains detailed rules for multi-layered structures and for trusts and similar legal arrangements. For certain higher-risk categories, the Commission can set a lower threshold. For families with companies in the EU this means: who is a beneficial owner will be answered more uniformly, but not more simply.
What it means for Swiss family offices
The AMLR does not apply in Switzerland. It still reaches Swiss actors in three ways. First, through companies, trusts and accounts in the EU, which are directly covered. Second, through EU banks and service providers passing the requirements on to their Swiss counterparties. Third, through Liechtenstein, which as an EEA state takes over EU anti-money laundering law via the EEA Agreement; those running structures there should follow the timing of the AMLR’s incorporation.
Preparation
To be ready by July 2027, check which parts of a family structure sit in the EU, which counterparties are based there and whether your own documentation withstands the uniform requirements. Comparing with the Swiss TJPG helps: both work with the 25 percent logic, but not with identical details. More in our article EU AMLR from July 2027.