AMLR 2027

Where do the AMLR and AMLD6 differ in practice?

The AMLR is an EU regulation and applies directly in every member state from 2027 — with no national transposition. AMLD6 is a directive that each member state must write into national law. The AMLR governs obliged entities' duties directly; AMLD6 governs, in addition, the national AML, FIU and supervisory architecture (registers, cooperation between authorities, whistleblower protection) and must be transposed by Spain. The criminal-law provisions on money laundering itself are largely set out in a separate directive (Directive (EU) 2018/1673) and should not be conflated with AMLD6.

AspectAMLR (Regulation 2024/1624)AMLD6 (Directive 2024/1640)
Legal formRegulation — directly applicableDirective — must be transposed
ApplicationFrom mid-2027Transposition deadline: 2027/2028
ContentObliged entities' duties, risk categories, substantive CDD/EDD rulesNational AML supervisory architecture, registers, cooperation between authorities, whistleblower protection
For agentsDirect change to KYC duties, PEP definition, cash limit, retentionIndirect, through Spanish transposing legislation
PenaltiesSubstantive infringement categories unified EU-wideNational penalty frameworks (amounts, procedures) are harmonised
DataAs a general rule 5 years' retention from the end of the business relationship (Art. 77), extendable by a competent authority in the individual case by a maximum of 5 further years — replaces Spain's current 10-year ruleAccess rights for law enforcement authorities

For the Spanish estate agent the AMLR matters immediately, because it applies directly. AMLD6 takes effect only once Spain writes it into Ley 10/2010 or a successor provision.

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

Practical tip: Focus on the AMLR through 2026/2027 — that is where the real shift is. Follow AMLD6 through the Spanish legislative process; it calls for no immediate action.

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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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