Is My Business Newly in Scope of the EU AMLR? A Checklist

Check whether the EU AMLR now covers your business: which sectors are new, the thresholds that apply, and the three first steps to take before July 2027.

Updated On October 21, 2026
Is My Business Newly in Scope of the EU AMLR? A Checklist

The EU's Anti-Money Laundering Regulation (AMLR) widens the list of businesses that must run anti-money laundering checks. From 10 July 2027 it covers banks and financial firms, plus a longer list of non-financial trades. Some of those trades have never had formal anti-money laundering duties. If you sell luxury goods or art, run a crowdfunding platform, broker loans, or work in football, this checklist is for you.

The AMLR is Regulation (EU) 2024/1624. It applies directly in every EU member state, with no national law needed. Our guide to the EU AMLR and AMLA explains the law and the new EU authority behind it. This checklist answers one narrower question: does the AMLR now apply to your business?

This guide is current as of 21 October 2026. Every threshold below was read from the regulation text and compared with the directive it replaces, Directive (EU) 2015/849.

Which businesses does the EU AMLR apply to?

The AMLR applies to every "obliged entity" listed in its Article 3. An obliged entity (sometimes called an obligated entity) is a business the law requires to run anti-money laundering checks. The list has three parts: credit institutions, financial institutions, and a set of named professions and trades. Most small businesses that are in scope fall into the third part.

The named professions and trades are [AMLR Art. 3(3)]:

  • Professional services: auditors, accountants, tax advisers, notaries, lawyers (for certain client transactions), and trust or company service providers.
  • Property: estate agents, including letting agents.
  • Goods: traders in precious metals and stones, high-value goods, and cultural goods such as art, plus businesses in free zones and customs warehouses.
  • Finance-adjacent: crowdfunding platforms, non-bank credit intermediaries, and investment-migration operators.
  • Others: gambling providers, non-financial mixed activity holding companies, football agents and professional football clubs.

Many of these were already covered by the current directive. The next section shows which ones are new.

Which businesses are newly in scope under the AMLR?

Six kinds of business appear in EU anti-money laundering law for the first time. Four more are covered more widely than before. The new ones are crowdfunding providers, non-bank credit intermediaries, investment-migration operators, non-financial mixed activity holding companies, football agents, and professional football clubs. The widened ones are traders in precious metals and stones, traders in high-value goods, cultural-goods dealers, and businesses in free zones.

BusinessWhen the AMLR applies to itUnder the current directiveApplies from
Crowdfunding service providers and intermediariesAlways [Art. 3(3)(h)]Not named10 July 2027
Credit intermediaries for mortgages and consumer loansWhen they are not banks or financial institutions, and do not act under the responsibility of a lender or another intermediary [Art. 3(3)(k)]Not named10 July 2027
Investment-migration operatorsWhen they help non-EU nationals obtain EU residence rights in exchange for investment [Art. 3(3)(l)]Not named10 July 2027
Non-financial mixed activity holding companiesA parent company, not itself a subsidiary, with at least one subsidiary on the trades list above [Arts. 2(1), 3(3)(m)]Not named10 July 2027
Football agentsAlways [Art. 3(3)(n)]Not named10 July 2029
Professional football clubsOnly for deals with investors, sponsors, agents or intermediaries, and for player transfers [Art. 3(3)(o)]Not named10 July 2029
Traders in precious metals and stonesTrading as a regular or main activity, however the customer pays [Art. 3(3)(e)]Only when paying or receiving €10,000 or more in cash10 July 2027
Traders in high-value goodsTrading as a regular or main activity in the goods listed below, however the customer pays [Art. 3(3)(f)]Only when paying or receiving €10,000 or more in cash10 July 2027
Cultural-goods dealers, galleries, auction housesDeals of €10,000 or more [Art. 3(3)(i)]Works of art only, at €10,000 or more10 July 2027
Free zones and customs warehousesStoring or trading cultural goods or high-value goods, in deals of €10,000 or more [Art. 3(3)(j)]Works of art in free ports only10 July 2027

The current-directive column comes from Article 2 of Directive 2015/849, as amended in 2018 [AMLD4 Art. 2(1)].

The biggest change for small firms is in luxury goods. Under the current directive, a jeweller or car dealer was only in scope when it took or paid €10,000 or more in cash. A dealer paid by bank transfer was outside. Under the AMLR, the trigger is the trade itself. A watch dealer paid entirely by card or transfer is in scope from 10 July 2027.

"High-value goods" has a fixed meaning. It covers only the goods in Annex IV of the AMLR, above these values:

GoodsCounts as high-value above
Jewellery, gold and silversmith articles€10,000
Clocks and watches€10,000
Motor vehicles€250,000
Aircraft€7,500,000
Watercraft (boats and yachts)€7,500,000

If selling goods above these values is a regular part of your business, you are likely in scope. The text does not say how often "regular" means. If you sell such goods only rarely, ask your national supervisor.

Two groups were already in scope and stay in scope. Accountants, tax advisers, lawyers, notaries, trust and company service providers, estate agents and gambling providers were covered before. Letting agents for rents of €10,000 or more a month were added in 2018. For all of these, the AMLR changes the detail of the duties, not whether they apply. Crypto-asset service providers were also already covered, as a type of financial institution [AMLR Art. 2(1)(6)].

One caution on the word "new". The current directive lets member states set stricter rules than it requires [AMLD4 Art. 5]. Your country may already cover your sector in its own law. "New" in this guide means new at EU level.

Am I in scope? A yes/no self-test

Answer each question for your business. If any answer is yes, you are probably an obliged entity from 10 July 2027. For football, the date is 10 July 2029. Questions 1 to 11 cover sectors that are new or widened. Question 12 covers sectors that were already in scope.

  1. Do you sell jewellery, watches or clocks worth more than €10,000 each, as a regular part of your business?
  2. Do you sell cars priced above €250,000, or aircraft or boats priced above €7,500,000?
  3. Do you trade in precious metals or precious stones as a regular or main activity?
  4. Do you sell or broker art or other cultural goods in deals of €10,000 or more?
  5. Do you store or trade art, cultural goods or high-value goods in a free zone or customs warehouse, in deals of €10,000 or more?
  6. Do you run a crowdfunding platform, or act as a crowdfunding intermediary?
  7. Do you broker mortgages or consumer loans in your own right, rather than under the responsibility of a lender or another broker?
  8. Do you help non-EU nationals obtain EU residence in exchange for investment?
  9. Is your company the top parent of a non-financial group, with at least one subsidiary that is in scope under this list?
  10. Are you a football agent?
  11. Are you a professional football club that deals with investors, sponsors or agents, or transfers players?
  12. Do you provide accounting, audit, tax, legal, notary, trust, company formation, estate agency or gambling services?

If every answer is no, the AMLR probably does not apply to you. EU sanctions law still does. Dealing with a sanctioned person is unlawful whether or not you are an obliged entity. Our guide to sanctions screening legal requirements explains that difference.

What must a business do first once it is in scope?

Three things come first: a written risk assessment, named people responsible for compliance, and customer checks that include sanctions and PEP screening [AMLR Arts. 10, 11, 20]. The rest of the AMLR builds on these three. They are a starting point, not a full programme.

1. Write a business-wide risk assessment. It must cover your money laundering, terrorist financing and sanctions-evasion risks, and match the size of your business [AMLR Art. 10(1)]. Look at your customers, products, payment methods and countries. AMLA has consulted on guidelines for this assessment. As of its 7 October 2026 update, the final guidelines were not yet published [AMLA].

2. Name your compliance manager and compliance officer. The compliance manager sits on the management body and is accountable for compliance. The compliance officer runs it day to day [AMLR Art. 11]. In a small firm, one person can hold both roles, alongside other work. A sole trader does these tasks personally [AMLR Art. 11(7)].

3. Set up customer due diligence. Customer due diligence means checking who your customer is before and during the relationship. You must identify and verify the customer and its beneficial owners, the people who ultimately own or control it. You must also check whether any of them are subject to targeted financial sanctions, meaning asset freezes and dealing bans on named people and companies [AMLR Art. 20(1)(d)]. That check includes anyone who controls the customer or owns more than 50% of it. You must also determine whether the customer or beneficial owner is a politically exposed person (PEP), such as a minister or senior judge, or a family member or close associate of one [AMLR Art. 20(1)(g)].

Dealers have one extra point to note. For traders in precious metals, high-value goods and cultural goods, the "customer" includes the supplier of the goods [AMLR Art. 19(6)(a)]. A watch dealer must check who it buys stock from, not only who it sells to.

Customer due diligence does not apply to every sale. It applies in these cases [AMLR Art. 19(1), (4)]:

SituationWhat is required
Starting a business relationshipFull customer due diligence
A one-off transaction of €10,000 or more, in one payment or linked paymentsFull customer due diligence
A one-off cash transaction of €3,000 or moreAt least identifying and verifying the customer
Any suspicion of money laundering or terrorist financingFull customer due diligence, whatever the amount

AMLA could have set lower thresholds for higher-risk sectors. Its final draft standards, dated 30 September 2026, set no extra lower thresholds for any sector [AMLA RTS Art. 19(9) final report]. Those standards still need adoption by the European Commission.

Screening customers against sanctions and PEP lists is one part of these duties. It does not make a business compliant on its own. Our guide to how sanctions screening works covers the process in more detail.

Does a small business have to do as much as a bank?

No. The AMLR has no size exemption, but it requires controls to match the firm's size and risk. Policies and controls must be "proportionate to the nature of the business, including its risks and complexity, and the size of the obliged entity" [AMLR Art. 9(1)]. A two-person gallery is not expected to run a bank's compliance department.

In practice, proportionality shrinks the paperwork, not the checks. A small firm's risk assessment can be short. One person can hold both compliance roles. But a sanctioned customer is the same problem for a jeweller as for a bank. Each customer check still has to happen.

A few narrow exemptions exist. Each one is a choice for the member state, not an automatic right:

  • Gambling: low-risk gambling services may be exempted, except casinos and most online gambling and betting [AMLR Art. 4].
  • Football clubs: top-division clubs with annual turnover under €5,000,000 in each of the previous two years, and lower-division clubs, may be exempted on proven low risk [AMLR Art. 5].
  • Occasional financial activity: a business that offers a financial service only occasionally, on a small scale, and only to its own customers may be exempted. Each transaction must be at most €1,000, and the activity at most 5% of turnover [AMLR Art. 6].

Frequently asked questions

Does the AMLR apply to my business if I am not in the EU? The AMLR applies to obliged entities operating in the EU. A business based outside the EU that serves EU customers should take advice on its own position, because the answer depends on how and where it operates. EU sanctions law can apply to it separately.

What happens if I am in scope and do nothing? Your national supervisor can impose fines and order you to fix your controls. For serious, repeated or systematic breaches, the maximum fine must be at least €1,000,000 or twice the benefit gained, whichever is higher [AMLD6 Art. 55(2)]. That is a ceiling, not a typical fine. Separately, dealing with a sanctioned person breaks EU sanctions law in its own right.

When do I need to be ready? By 10 July 2027 for most sectors, and 10 July 2029 for football agents and clubs [AMLR Art. 90]. Our EU AMLR timeline lists every key date from 2024 to 2029.

Is there a size threshold that exempts small businesses entirely? No. The AMLR has no general size exemption. It does require controls to be proportionate to size and risk, and it lets one person hold both compliance roles in a small firm. Member states may exempt a few narrow cases, such as small football clubs and low-risk gambling.

I already follow my country's anti-money laundering law. What changes? Mostly the detail. The AMLR writes sanctions checks into customer due diligence, sets the beneficial ownership threshold at 25% or more, and caps how long customer data can go without a refresh. Our AMLR and AMLA guide has the full comparison table.

Who should I ask if I am still unsure? Your national anti-money laundering supervisor. Which body that is depends on your country and sector, so check your national supervisor's own website. A qualified adviser can also review your activities against Article 3.

Citations

Getting the screening part right

If the self-test put you in scope, customer checks are the step most firms cannot do by hand. Sanctions lists change often, and the AMLR expects you to re-check customers over time, not just once.

DeRisk Hub screens customers, beneficial owners and suppliers against sanctions, export-control and PEP list sources. It re-screens the entities you monitor as lists update, and it records every decision in an audit trail you can show a supervisor. It is one part of a compliance programme, not the whole of one. See what screening costs, start your free trial (15 days, 100 entities, no credit card required), or go to DeRiskHub.com.

This article is informational and does not constitute legal advice. It describes the scope of Regulation (EU) 2024/1624 as verified against the legal texts and AMLA's published material on 21 October 2026. National rules and AMLA standards will add detail. Confirm whether the AMLR applies to your business with your national supervisor or qualified counsel.