EU anti-money laundering framework, regulatory instruments and Dutch implementation 
Last updated: 16 September 2026 
The new EU anti-money laundering package establishes an AML/CFT single rulebook and supervisory framework, consisting of Anti-Money Laundering Regulation (AMLR) and the Sixth Anti-Money Laundering Directive (AMLD6), the Anti-Money Laundering Authority (AMLA) Regulation established together with Regulation (EU) 2023/1113 on transfers of funds and crypto-assets. The AMLR will for the most part apply from 10 July 2027, AMLD6 must generally be transposed by that date, and AMLA is preparing for direct supervision from 2028.  
This overview brings together the principal EU legislation, AMLA regulatory instruments and consultations, transitional instruments and Dutch implementation materials. 
European legislation  Dutch implementation and parliamentary materials
The Dutch implementation act implements AMLD6 and the AMLR at statutory level. According to the Dutch Legislative Calendar, the Wwft will be repealed and, among other legislation, the Wtt 2018, Wft, Handelsregisterwet 2007 and Advocatenwet will be amended. AMLA guidelines, RTS, ITS and consultations 
AMLA Regulatory Instruments overview  |  AMLA planning for RTS/ITS/GL 2026–2028 (Annex XI) 
Final reports published  Open consultations  Consultations closed - final report or final guidelines not yet published  Planned instruments - no separate public document as of current date 
RTS - AMLA Regulation Article 11(6): central AML/CFT database - procedures, formats, timelines and materiality criteria  
GL - AMLD6 Article 53(11): base amounts for pecuniary sanctions in proportion to turnover, by type of breach and category of obliged entity  Statutory deadline 10 July 2026; AMLA planning: final Q4 2026 
GL - AMLR Article 20(3): risk variables and risk factors when entering into business relationships and carrying out occasional transactions  Statutory deadline 10 July 2026; AMLA planning: consultation Q3 2026; final Q4 2026 
RTS - AMLD6 Article 41(2): criteria for the designation and functions of central contact points  Statutory deadline 10 July 2026; AMLA planning: consultation Q3 2026; final Q4 2026 
RTS - AMLD6 Article 50(13): AML/CFT supervisory colleges in the non-financial sector  Statutory deadline 10 July 2026; AMLA planning: consultation Q4 2026; final Q1 2027 
RTS - AMLD6 Article 49(14): AML/CFT supervisory colleges in the financial sector  Statutory deadline 10 July 2026; AMLA planning: consultation Q4 2026; final Q1 2027 
GL - AMLR Article 9(4): scope and organisation of internal AML/CFT policies, procedures, controls and compliance functions  Statutory deadline 10 July 2026; AMLA planning: consultation Q1 2027; final Q2 2027 
Commission delegated act - AMLR Article 68(2): categories of breaches and persons liable, indicators of gravity and criteria for setting penalties Statutory deadline 10 July 2026; no separate adopted act identified in the supplied materials 
Further future AMLA mandates 
GL - AMLR Article 18(8): outsourcing arrangements, governance, responsibilities and oversight of outsourced critical functions  By 10 July 2027 
Joint GL - AMLR Article 21(4): AMLA/EBA guidelines on AML/CFT compliance and access to financial services, including de-risking  By 10 July 2027 
GL - AMLR Article 32(1): ML/TF risks, trends and methods relating to geographical areas outside the EU  By 10 July 2027 
GL - AMLR Article 34(5): determining whether a customer holds total assets of at least EUR 50 million and the valuation of those assets  By 10 July 2027 
GL - AMLR Article 37(3): risk assessment and risk-mitigating measures by CASPs in correspondent relationships with third-country counterparties  By 10 July 2027 
GL - AMLR Article 40(2): measures for transfers of crypto-assets from or to self-hosted addresses  By 10 July 2027 
GL - AMLR Article 42(2): politically exposed persons - close associates and risk assessment of PEP categories, family members and close associates  By 10 July 2027 
GL - AMLR Article 50: reliance on customer due diligence performed by other obliged entities  By 10 July 2027 
GL - AMLR Article 69(5): indicators of suspicious activities or behaviour  By 10 July 2027 
Joint GL - AMLR Article 75: AMLA/EDPB guidelines on information-sharing partnerships and data protection; Public consultation announced for the first half of 2027  AMLA/EDPB announcement (1 July 2026) 
GL - AMLD6 Article 19(10): operational autonomy and independence of FIUs; operational and strategic analysis and powers  By 10 July 2028 
REC - AMLD6 Article 28: best practices for feedback by FIUs to obliged entities  By 10 July 2028 
GL - AMLD6 Article 31(4): procedures for transmitting, receiving and following up on cross-border STR information between FIUs  By 10 July 2028 
GL - AMLD6 Article 40(3): risk-based approach to AML/CFT supervision  By 10 July 2028 
GL - AMLD6 Article 6(8): fit and proper - good repute, honesty, integrity, knowledge and expertise  By 10 July 2029 
ITS - AMLD6 Article 51(4): template for cooperation agreements between EU supervisors and third-country supervisory authorities  By 10 July 2029 
GL - AMLD6 Article 64(6): cooperation between financial AML/CFT supervisors and other relevant authorities  By 10 July 2029 
GL - AMLD6 Article 69: broad AML/CFT cooperation between supervisors, the ECB, ESAs, Europol, Eurojust and the EPPO  By 10 July 2029 
EBA / European Commission - transitional instruments 
Certain existing EBA guidelines and technical standards continue to apply until AMLA instruments on the same subject enter into force (Article 54(5) of the AMLA Regulation).  
Commission Delegated Regulation (EU) 2019/758 - measures where the law of a third country does not permit group-wide AML/CFT policies  Existing / transitional instrument; AMLD5 Article 45(6) 
Commission Delegated Regulation (EU) 2018/1108 - criteria and functions of a central contact point for e-money issuers and payment service providers  Existing / transitional instrument; AMLD5 Article 45(9) 
Commission Delegated Regulation (EU) 2024/595 - central AML/CFT database (EuReCA)  Existing / transitional instrument; EBA Regulation Article 9a

What is the AMLR? 
The Anti-Money Laundering Regulation (AMLR) is one of the new EU anti-money laundering and counter-terrorist financing framework instruments. Together with the Sixth Anti-Money Laundering Directive (AMLD6), the AMLA Regulation and Regulation (EU) 2023/1113 on transfers of funds and crypto-assets, replace and further develop the existing AML framework. 
The main AML/CFT obligations imposed on businesses will now be contained in a directly applicable EU regulation. Under the current system, the AML directives are implemented separately in each Member State, which has resulted in differences in wording, scope and interpretation.  
The AMLR is intended to create a more harmonised European rulebook covering matters such as customer due diligence, beneficial ownership, internal controls, ongoing monitoring and the reporting of suspicious transactions.  
AMLD6, by contrast, mainly governs matters requiring national implementation, such as the organization and powers of national supervisors, Financial Intelligence Units and national registers. 
The AMLR also changes the scope of the AML regime. Certain entities that are currently outside the Dutch Wwft may become obliged entities, while new categories expressly include, among others, crowdfunding service providers, certain credit intermediaries and investment migration operators.  
The Regulation also introduces specific rules for holding companies, crypto-asset service providers and a Union-wide limit on cash payments.

When does the AMLR apply? 
The principal legislation forming the new EU AML framework was adopted in 2023 and 2024. The AMLR will, for the most part, apply from 10 July 2027, while AMLD6 must generally be transposed by that date. Because the AMLR is a regulation, its substantive requirements will apply directly in the Netherlands.  
Dutch institutions will increasingly have to look directly to the AMLR, Commission delegated and implementing acts, and AMLA's regulatory technical standards and guidelines rather than primarily to Dutch legislative history and national supervisory guidance. 
The Dutch legislative process is, however, still ongoing and the proposed legislation remains subject to change. 
 
​What role will AMLA play? 
The new Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) took over the European Banking Authority's AML/CFT mandates on 1 January 2026. AMLA will develop many of the technical standards and guidelines that further specify the AMLR and AMLD6 and will also promote consistent supervision across the EU. AMLA will directly supervise a limited group of higher-risk credit and financial institutions and groups operating across several Member States. Other obliged entities will remain under national supervision, although AMLA's standards and guidelines will also shape the way national authorities apply the new framework.