AMLR 2027

What does the AMLR 2027 change in practice for agents?

The AMLR (Regulation (EU) 2024/1624) applies from 2027 and considerably widens the duties on estate agents: a single PEP definition, an EU-wide cash ceiling, extended record-keeping, crypto-assets as a risk category in their own right, and the new EU authority AMLA — which, however, directly supervises only selected high-risk financial firms.

The AMLR is expected to take effect in mid-2027 (after a two-year transitional period from June 2024). For Spanish estate agents that means:

  1. Cash ceiling: Art. 80 AMLR introduces an EU-wide ceiling on cash payments, covering deposits, reservations and price payments as well. Member states may keep stricter national limits — Spain already applies a lower threshold today. We do not state the specific figure here; what matters is which of the two limits is the lower one in the case at hand. Position as at 10/2026, to be updated.
  2. PEP definition: uniform EU criteria, covering domestic PEPs (Spanish politicians) and their family members too.
  3. Crypto-assets: crypto is captured as a risk category in its own right. Funding a purchase from crypto wealth will generally establish an elevated risk and therefore a deeper review — though the actual classification remains a risk-based, case-by-case assessment, not an automatic consequence.
  4. The AMLA authority: the new body in Frankfurt directly supervises a limited set of high-risk financial firms; ordinary agencies remain with SEPBLAC.
  5. Existing clients: the AMLR applies to all clients, not only those onboarded after 2027. Existing files must be brought up to standard.
  6. Data retention: the AMLR lowers the general EU-wide period to 5 years (Art. 77) — in Spain, 10 years still applies today under Art. 25 Ley 10/2010. An extension ordered by an authority in an individual case is possible (5 further years at most).
  7. Group-wide compliance: agencies with several offices will have to produce group-wide risk analyses.

Legal basis: Regulation (EU) 2024/1624; AMLD6 (Directive (EU) 2024/1640)

Practical tip: Get the office ready during 2026: check your existing client files for completeness, because from 2027 the whole back book has to be brought into line. The cash ceiling affects many international buyers who bring cash reserves with them.

AI-assisted tools were used in preparing these FAQs; the content was subsequently reviewed and approved by the Doxario editorial team. They reflect the general state of the law as at the review date shown and do not constitute individual legal or tax advice. To assess your own case — particularly where complex structures are involved (offshore companies, trusts, foundations, communities of heirs) or where the new EU rules leave room for doubt — we recommend consulting a lawyer specialising in Spanish anti-money-laundering law and, on tax questions, a tax adviser. Doxario is a deal management and compliance platform for estate agents in Spain, operated by Blue Pepper S.L.; we therefore have an economic interest in the solutions described in these FAQs. Doxario accepts no liability for decisions taken solely on the basis of these FAQs.

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