AMLR — stricter legal requirements under the new EU regulation

EU anti-money-laundering law has until now reached firms indirectly: directives set goals, and each member state wrote its own rules to meet them. That construction is being retired. The new AML package — the Anti-Money Laundering Regulation (AMLR), a sixth directive (AMLD6) and the regulation establishing the EU authority AMLA — moves the substantive obligations into a regulation that applies directly and identically across the union. For obliged entities, including accounting and audit firms, this is not a reorganisation of the same requirements. On several points, the requirements get stricter.

Why a regulation is a different animal

A directive tolerates national variation; a regulation does not. When AMLR starts to apply in 2027, its provisions take precedence over conflicting national law and need no Swedish implementation to bind Swedish firms. The room that national legislators and supervisors have had to soften or reinterpret EU requirements disappears, and with it the differences between member states that have made EU-wide AML enforcement uneven.

Where the law tightens

The regulation makes customer due diligence more prescriptive: which identity data must be collected, how verification is done, and what simplified and enhanced measures require. Beneficial ownership gets a fixed threshold — 25 per cent ownership or control by other means — together with an explicit duty to investigate ownership chains rather than rely on register entries. Politically exposed persons must be identified and handled with enhanced measures throughout the relationship. An EU-wide cap on cash payments of 10,000 euro is introduced. And record-keeping requirements are sharpened, with documentation retained and retrievable for five years.

AMLA raises the cost of falling short

The package also changes who watches. AMLA, the new EU anti-money-laundering authority, directly supervises a set of high-risk financial institutions and — more importantly for everyone else — writes the technical standards and guidelines that national supervisors must apply. Supervision of accounting and audit firms stays with the Swedish authorities, but the yardstick becomes European, and the sanction framework behind it allows substantially higher penalties than firms have been used to.

The direction for Swedish firms

Much of what AMLR demands is recognisable from the Swedish Anti-Money Laundering Act — the risk-based approach, due diligence, monitoring, reporting. What changes is the precision of the requirements and the uniformity of their enforcement. The firms that will find 2027 uneventful are those whose client files, risk assessments and decision trails are already structured enough to be shown, item by item, against a checklist. That standard of traceability is what the new rulebook makes mandatory — and what a purpose-built system is for.