AMLR vs AMLD6 vs AMLAR: the three EU instruments, untangled

If you run an Irish accountancy practice, law firm, estate agency or trust and company service provider, you have probably seen three unfamiliar acronyms turning up in supervisor bulletins and professional-body newsletters: AMLR, AMLD6 and AMLA (or AMLAR). They are routinely lumped together as "the new EU AML package", which makes it hard to work out what actually applies to your firm, and when.

The distinction matters. One of the three instruments will directly rewrite the rulebook your firm works under from 10 July 2027. The other two mostly change the machinery around you — supervisors, registers and a new EU authority. This post untangles them in plain English.

The one-line version

• Regulation (EU) 2024/1624 (AMLR) — the "single rulebook". The rules your firm must follow: customer due diligence, beneficial ownership, internal controls, reporting. Directly applicable across the EU from 10 July 2027, with no Irish transposition needed.
• Directive (EU) 2024/1640 (AMLD6) — the institutional layer. National supervisors, FIU powers, beneficial-ownership registers, cross-border cooperation. Ireland must transpose it, generally by 10 July 2027.
• Regulation (EU) 2024/1620 (AMLAR) — the instrument that creates AMLA, the EU Anti-Money Laundering Authority in Frankfurt. AMLA has been operational since 1 July 2025 and is now producing the technical standards and guidelines that put flesh on the AMLR.

If you only remember one thing: the AMLR is the one that changes your day-to-day obligations. The other two shape who supervises you and how strictly.

AMLR: the single rulebook that replaces your current obligations

Under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010), your firm has been a "designated person" for well over a decade. The AMLR uses a different term — "obliged entity" — but for most Irish firms already in scope it describes the same population, and then some.

The critical feature of the AMLR is its legal form. It is a regulation, not a directive. Previous EU AML directives had to be transposed into Irish law, which is how the CJA 2010 framework came about. The AMLR skips that step: from 10 July 2027 it applies directly, word for word, in Ireland and every other member state. Your substantive obligations will come from the regulation itself rather than from an Irish Act interpreting a directive.

That is why your existing CJA 2010-era documentation cannot simply roll forward. Headline changes in the AMLR include:

• The customer due diligence threshold for occasional transactions drops to 10,000 euro (from 15,000 euro), and occasional cash transactions of 3,000 euro or more trigger limited CDD.
• An EU-wide cash payment cap of 10,000 euro for commercial transactions, covering single or linked operations.
• A harmonised beneficial-ownership test: 25% or more ownership interest, direct or indirect, applied the same way EU-wide.
• Prescribed compliance roles: a board-level compliance manager plus a compliance officer of sufficiently high standing. From 10 July 2027 the compliance officer is also responsible for implementing targeted financial sanctions.
• Enhanced due diligence rules for high-net-worth relationships (assets of 5 million euro or more handled for a client whose total wealth is 50 million euro or more).
• FIU information requests must generally be answered within 5 working days.
• Records retained for 5 years, then deleted — deletion becomes an obligation, not an afterthought.

You can read the full text of the AMLR on EUR-Lex, and our AMLR explainer walks through the changes sector by sector.

AMLD6: the plumbing behind the scenes

Directive (EU) 2024/1640 (AMLD6) is easy to confuse with the AMLR because they were adopted as a package. But AMLD6 does a different job. It governs the institutional framework: how member states organise national supervision, what powers FIUs hold, how beneficial-ownership registers operate, and how authorities cooperate across borders.

Because it is a directive, Ireland must transpose it into national law — generally by 10 July 2027, although the beneficial-ownership register provisions were staggered earlier (register access from 10 July 2025; the core register articles and technical standards from 10 July 2026). One practical consequence: AMLD6 connects BO registers EU-wide and gives registrars new verification powers, which affects the register data your firm relies on when checking RBO extracts before taking on a new client.

What AMLD6 does not do is change your firm's CDD steps or record-keeping duties. Those live in the AMLR. Where AMLD6 will touch you is through your supervisor — whether that is the PSRA, the Law Society of Ireland, one of the designated accountancy bodies (Chartered Accountants Ireland, ACCA, CPA Ireland), the AMLCU at the Department of Justice, or the Central Bank of Ireland — because the directive shapes how those supervisors are organised and what is expected of them.

AMLAR: a new supervisor of supervisors

Regulation (EU) 2024/1620 (AMLAR) establishes AMLA, the EU Anti-Money Laundering Authority, based in Frankfurt. AMLA has been operational since 1 July 2025.

Will AMLA supervise your firm directly? Almost certainly not. Its direct supervision is aimed at up to roughly 40 high-risk, cross-border financial institutions, starting from 2028. A solicitor's practice in Cork or a letting agency in Galway is not in that population.

So why should you care? Two reasons.

1. AMLA writes the detail. Around 23 regulatory and implementing technical standards and guideline mandates were mostly due around 10 July 2026 — meaning they are landing now. These will spell out exactly how AMLR obligations are to be applied in practice. Keep an eye on amla.europa.eu, and expect your supervisor's guidance to follow.
2. AMLA drives consistency in national enforcement. Part of its job is to push national supervisors towards a tougher, more uniform standard. Even though AMLA will never inspect your firm, its influence will reach you through the PSRA, the Law Society, the accountancy bodies, the AMLCU and the Central Bank.

What stays Irish

The three instruments do not sweep away everything national. Your supervisor remains an Irish body. Suspicious transaction reports remain dual-reported in Ireland — to FIU Ireland via the goAML portal (fiu-ireland.ie) and to the Revenue Commissioners via ROS. Ireland's beneficial-ownership registers, including the RBO, remain the registers you check. And Ireland has no threshold transaction reporting regime — the AMLR does not introduce one either.

What to do now

1. Note the date that matters: 10 July 2027, when the AMLR applies. Work back from it.
2. Confirm which supervisor your firm answers to, and subscribe to its AML updates.
3. Pull out your current CJA 2010-era policies and business-wide risk assessment. List every threshold, definition and procedure they contain — each will need checking against the AMLR.
4. Decide who will hold the two prescribed compliance roles: the board-level compliance manager and the compliance officer.
5. Watch AMLA's technical standards as they land — they will determine how much detail your refreshed programme needs.
6. Diarise a formal gap analysis for the second half of 2026, so remediation work is spread over months rather than crammed into the final quarter.

Where CompliDesk fits

CompliDesk Ireland is being built AMLR-native — templates, thresholds and workflows written to Regulation (EU) 2024/1624 from day one, not retrofitted from the old directives. If you want a structured starting point, work through our free AMLR readiness checklist.