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The EU Anti-Money Laundering Directive and Regulation: A Commentary

Georgios Pavlidis

ISBN13: 9781035347094
To be Published: August 2026
Publisher: Edward Elgar Publishing Limited
Country of Publication: UK
Format: Hardback
Price: £310.00





This Commentary presents a structured and accessible explanation of the European Union’s framework for preventing money laundering and terrorist financing. It provides detailed commentary on the Sixth Anti-Money Laundering Directive (AMLD6) and the Anti-Money Laundering Regulation (AMLR), explaining how these rules strengthen cooperation between authorities, improve transparency and hold both individuals and companies accountable.

Key Features:

  • Includes forward-looking reflections on the coherence, effectiveness and future direction of the EU’s AML/Countering the Financing of Terrorism framework
  • Outlines the interactions between AML law and other EU instruments, including data protection, financial supervision and criminal law
  • Analyses the impact of this framework on financial integrity and the rule of law, as well as how they protect the public from the misuse of the financial system

Presenting an in-depth, article-by-article analysis of the AMLD6 and AMLR, this Commentary is an essential read for regulators, policymakers, compliance officers and legal practitioners. It is also highly relevant to legal scholars and academics interested in understanding the legislative intent, legal obligations and institutional design of the AML framework.

Subjects:
Money Laundering
Contents:
Introduction to the EU Anti-Money Laundering Directive and Regulation

PART I COMMENTARY ON THE 6TH ANTI-MONEY LAUNDERING DIRECTIVE
1. Article 1: Subject matter
2. Article 2: Definitions
3. Article 3: Identification of exposed sectors at national level
4. Article 4: Requirements relating to certain service providers
5. Article 5: Requirements relating to the granting of residence rights in exchange for investment
6. Article 6: Checks on the senior management and beneficial owners of certain obliged entities
7. Article 7: Risk assessment at Union level
8. Article 8: National risk assessment
9. Article 9: Statistics
10. Article 10: Central beneficial ownership registers
11. Article 11: General rules regarding access to beneficial ownership registers by competent authorities, self-regulatory bodies, and obliged entities
12. Article 12: Specific access rules to beneficial ownership registers for persons with legitimate interest
13. Article 13: Procedure for the verification and mutual recognition of a legitimate interest to access beneficial ownership information
14. Article 14: Templates and procedures
15. Article 15: Exceptions to the access rules to beneficial ownership registers
16. Article 16: Bank account registers and electronic data retrieval systems
17. Article 17: Implementing acts for the interconnection of registers
18. Article 18: Single access point to real estate information
19. Article 19: Establishment of the FIU
20. Article 20: Fundamental rights officer
21. Article 21: Access to information
22. Article 22: Responses to requests for information
23. Article 23: Provision of information to supervisors
24. Article 24: Suspension or withholding of consent
25. Article 25: Instructions to monitor transactions or activities
26. Article 26: Alerts to obliged entities
27. Article 27: FIU annual report
28. Article 28: Feedback by FIU
29. Article 29: Cooperation between FIUs
30. Article 30: Protected channels of communication
31. Article 31: Exchange of information between FIUs
32. Article 32: Joint analyses
33. Article 33: Use by FIUs of information exchanged between them
34. Article 34: Consent to further dissemination of information exchanged between FIUs
35. Article 35: Effect of criminal law provisions
36. Article 36: Confidentiality of reporting
37. Article 37: powers and resources of national supervisors
38. Article 38: Supervision of forms of infrastructure of certain intermediaries operating under the free-
dom to provide services
39. Article 39: Provision of information to obliged entities
40. Article 40: Risk-based supervision
41. Article 41: Central contact points
42. Article 42: Disclosure to FIUs
43. Article 43: Provision of information to FIUs
44. Article 44: General principles regarding supervisory cooperation
45. Article 45: Provision of information on cross-border activities
46. Article 46: Provisions related to cooperation in the context of group supervision
47. Article 47: Supervisory cooperation regarding obliged entities carrying out cross-border activities
48. Article 48: Exchange of information in relation to implementation of group policies in third countries 266
49. Article 49: AML/CFT supervisory colleges in the financial sector
50. Article 50: AML/CFT supervisory colleges in the non-financial sector
51. Article 51: Cooperation with supervisors in third countries
52. Article 52: Oversight of self-regulatory bodies
53. Article 53: General provisions
54. Article 54: Supervisory measures towards establishments of obliged entities and certain activities
carried out under the freedom to provide services
55. Article 55: Pecuniary sanctions
56. Article 56: Administrative measures
57. Article 57: Periodic penalty payments
58. Article 58: Publication of pecuniary sanctions, administrative measures, and periodic penalty payments
59. Article 59: Exchange of information on pecuniary sanctions and administrative measures
60. Article 60: Reporting of breaches and protection of reporting persons
61. Article 61: General provisions
62. Article 62: Communication of the list of the competent authorities
63. Article 63: Cooperation with AMLA
64. Article 64: Cooperation in relation to credit institutions or financial institutions
65. Article 65: Cooperation in relation to auditors
66. Article 66: Cooperation with authorities in charge of implementing targeted financial sanctions
67. Article 67: professional secrecy requirements
68. Article 68: Exchange of information among supervisors and with other authorities
69. Article 69: AML/CFT cooperation guidelines
70. Article 70: Processing of certain categories of personal data
71. Article 71: Exercise of the delegation
72. Article 72: Committee procedure
73. Article 73: Transitional management of FIU.n et
74. Article 74: Amendments to Directive (EU) 2015/849
75. Article 75: Amendment to Directive (EU) No 2019/1937
76. Article 76: Review
77. Article 77: Repeal
78. Article 78: Transposition
79. Article 79: Entry into force
80. Article 80: Addressees

PART II COMMENTARY ON THE ANTI-MONEY LAUNDERING REGULATION
81. Article 1: Subject matter
82. Article 2: Definitions
83. Article 3: Obliged entities
84. Article 4: Exemptions for certain providers of gambling services
85. Article 5: Exemptions for certain professional football clubs
86. Article 6: Exemptions for certain financial activities
87. Article 7: Prior notification of exemptions
88. Article 8: Notification of cross-border operations and application of national law
89. Article 9: Scope of internal policies, procedures and controls
90. Article 10: Business-wide risk assessment
91. Article 11: Compliance functions
92. Article 12: Awareness of requirements
93. Article 13: Integrity of employees
94. Article 14: Reporting of breaches and protection of reporting persons
95. Article 15: Situation of specific employees
96. Article 16: Group-wide requirements
97. Article 17: Branches and subsidiaries in third countries
98. Article 18: Outsourcing
99. Article 19: Application of customer due diligence measures
100. Article 20: Customer due diligence measures
101. Article 21: Inability to comply with the requirement to apply customer due diligence measures
102. Article 22: Identification and verification of the identity of customers and beneficial owners
103. Article 23: Timing of the verification of the customer and beneficial owner identity
104. Article 24: Reporting of discrepancies with information contained in beneficial ownership registers
105. Article 25: Identification of the purpose and intended nature of a business relationship or occasional transaction
106. Article 26: Ongoing monitoring of the business relationship and monitoring of transactions performed by customers
107. Article 27: Temporary measures for customers subject to UN financial sanctions
108. Article 28: Regulatory technical standards on the information necessary for the performance of
customer due diligence
109. Article 29: Identification of third countries with significant strategic deficiencies in their national
AML/CFT regimes
110. Article 30: Identification of third countries with compliance weaknesses in their national AML/CFT
regimes
111. Article 31: Identification of third countries posing a specific and serious threat to the Union’s financial system
112. Article 32: Guidelines on money laundering and terrorist financing risks, trends, and methods 596
113. Article 33: Simplified due diligence measures
114. Article 34: Scope of application of enhanced due diligence measures
115. Article 35: Countermeasures to mitigate money laundering and terrorist financing threats from
outside the Union
116. Article 36: Specific enhanced due diligence measures for cross-border correspondent relationships
117. Article 37: Specific enhanced due diligence measures for cross-border correspondent relationships
for crypto-asset service providers
118. Article 38: Specific measures for individual third-country respondent institutions
119. Article 39: Prohibition of correspondent relationships with shell institutions
120. Article 40: Measures to mitigate risks in relation to transactions with a self-hosted address
121. Article 41: Specific provisions regarding applicants for residence by investment schemes
122. Article 42: Specific provisions regarding politically exposed persons
123. Article 43: List of prominent public functions
124. Article 44: Politically exposed persons who are beneficiaries of insurance policies
125. Article 45: Measures for persons who cease to be politically exposed persons
126. Article 46: Family members and persons known to be close associates of politically exposed persons
127. Article 47: Specifications for the life and other investment-related insurance sector
128. Article 48: General provisions relating to reliance on other obliged entities
129. Article 49: Process of reliance on another obliged entity
130. Article 50: Guidelines on reliance on other obliged entities
131. Article 51: Identification of beneficial owners for legal entities
132. Article 52: Beneficial ownership through ownership interest
133. Article 53: Beneficial ownership through control
134. Article 54: Coexistence of ownership interest and control in the ownership structure
135. Article 55: Ownership structures involving legal arrangements or similar legal entities
136. Article 56: Notifications
137. Article 57: Identification of beneficial owners for legal entities similar to express trusts
138. Article 58: Identification of beneficial owners for express trusts and similar legal arrangements
139. Article 59: Identification of a class of beneficiaries
140. Article 60: Identification of objects of a power and default takers in discretionary trusts
141. Article 61: Identification of beneficial owners of collective investment undertakings
142. Article 62: Beneficial ownership information
143. Article 63: Obligations of legal entities
144. Article 64: Trustee obligations
145. Article 65: Exceptions to obligations of legal entities and legal arrangements
146. Article 66: Nominee obligations
147. Article 67: Foreign legal entities and foreign legal arrangements
148. Article 68: Penalties
149. Article 69: Reporting of suspicions
150. Article 70: Specific provisions for reporting of suspicions by certain categories of obliged entities
151. Article 71: Refraining from carrying out transactions
152. Article 72: Disclosure to FIU
153. Article 73: Prohibition of disclosure
154. Article 74: Threshold-based reports of transactions in certain high-value goods
155. Article 75: Exchange of information in the framework of partnerships for information sharing
156. Article 76: Processing of personal data
157. Article 77: Record retention
158. Article 78: Provision of records to competent authorities
159. Article 79: Anonymous accounts and bearer shares and bearer share warrants
160. Article 80: Limits to large cash payments in exchange for goods or services
161. Article 81: Cooperation between FIUs and the EPPO
162. Article 82: Requests for information to the EPPO
163. Article 83: Cooperation between FIUs and OLAF
164. Article 84: Requests for information to OLAF
165. Article 85: Exercise of the delegation
166. Article 86: Committee procedure
167. Article 87: Review
168. Article 88: Reports
169. Article 89: Relation to Directive (EU) 2015/849
170. Article 90: Entry into force and application