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ARTICLE · 17 JULY 2026

What's Done, What's Due: The AML Countdown

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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On 10 July 2027 – one year from now – the Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR) and the Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 (AMLAR)...

GermanyGovernment, Public Sector
Kai Liebrich
Kai Liebrich
Dr Timo Bühler
Dr Timo Bühler
Sophia Peter
Sophia Peter
Thorben Schlingmann
Thorben Schlingmann
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On 10 July 2027 – one year from now – the Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR) and the Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 (AMLAR) will become directly applicable across all EU Member States, and the Sixth Anti-Money Laundering Directive1 (AMLD6) must be transposed into national law2.

Here is an overview of the steps that regulators and stakeholders have already completed, what still lies ahead and what is currently being discussed in the run-up to the new regulatory framework:

1. RTS and Guidelines: Is there enough time to prepare?

Obliged entities are currently preparing for the upcoming changes in the AML regime. They invest significant time and effort into conducting gap analyses, aligning internal processes and establishing new policies to be ready by the time the new AML package becomes applicable.

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