5AMLD is often read as a rulebook a firm follows, but no firm complies with "5AMLD" directly. It is an amending directive: Directive (EU) 2018/843 changed the fourth directive, 2015/849, and each member state wrote those changes into its own AML law. A firm in Dublin follows Irish law, one in Milan Italian law.
What is the 5th EU Anti-Money Laundering Directive?
The 5th EU Anti-Money Laundering Directive, also written AMLD5 or AMLD 5, is Directive (EU) 2018/843 of 30 May 2018. It was published in the Official Journal on 19 June 2018, entered into force on the twentieth day after that, and gave member states until 10 January 2020 to apply it (Article 4). What it amended was Directive (EU) 2015/849, the fourth directive, so a lawyer reads the two together.
Its recitals give the reason. "Recent terrorist attacks" had shown new ways of financing terrorism, and anonymous prepaid cards were "easy to use in financing terrorist attacks and logistics". The changes that follow cover virtual currency, prepaid cards, beneficial ownership and high value trade.
In an AML program, the policy cites the national law that carries 5AMLD, and the controls it drove (customer due diligence for new sectors, register checks, PEP lists, enhanced due diligence for listed countries) sit in onboarding and screening.
What did 5AMLD change?
- Cryptocurrency. Providers of exchange between virtual and fiat currencies and custodian wallet providers became obliged entities, so they now identify customers and report suspicion. Crypto transfers later gained the travel rule as well.
- Prepaid cards. The due diligence exemption for anonymous cards shrank to EUR 150 stored, or EUR 150 a month on a reloadable card used in one member state, and remote payments over EUR 50 lose it (Article 12 as amended).
- UBOs and PEPs. Beneficial ownership registers opened to "any member of the general public" (Article 30(5)(c)), trust registers followed, and each member state had to publish a list of the functions that count as prominent public functions (Article 20a), which PEP screening draws on.
- Luxury goods. Art traders, galleries and auction houses became obliged entities for transactions of EUR 10,000 or more, as did letting agents for monthly rents of EUR 10,000 or more. Picture a gallery (illustrative) that sells a EUR 12,000 painting: since 2020 it identifies the buyer and the beneficial owner, keeps the record and reports suspicion like a bank.
- High risk third countries. Article 18a set out the enhanced due diligence for relationships with the high risk third countries the Commission identifies under Article 9, the EU's own list.
- Legislation and registers. Transposition by 10 January 2020, beneficial ownership registers for companies by the same date, trust registers by 10 March 2020, central bank account mechanisms by 10 September 2020 and register interconnection by 10 March 2021 (Article 4 and recital 53).
What did the Court of Justice decide about public UBO registers?
A Luxembourg company, Sovim, and a beneficial owner asked Luxembourg Business Registers to restrict public access to their register entries. On 22 November 2022 the Court of Justice ruled, in Joined Cases C-37/20 and C-601/20, that the 5AMLD provision opening registers to the general public "is invalid", because the interference with privacy is "neither limited to what is strictly necessary nor proportionate" (press release 188/22).
The ruling took out one change and left the rest. Obliged entities kept register access for customer due diligence, which is how UBO verification still starts. Directive (EU) 2024/1640, known as AMLD6, brings public access back only for people who show "a legitimate interest" (Article 12), due in national law by 10 July 2026.
From 10 July 2027, where a company files a statement that its ultimate beneficial owner could not be determined, an obliged entity sees that statement only after it reports a discrepancy or shows the steps it took (Article 10(5)). So the file that counts is the firm's own register check and discrepancy report, and a public search adds little to it. complead, formerly Sanction Scanner, confirms an entity against official registers in its KYB and UBO verification, follows owners up the chain to natural persons and shows where every field came from.
Is 5AMLD still in force, and what takes over in 2027?
Table 1. What 5AMLD changed and where each change stands (as of October 2026).
| Change | What 5AMLD did | Article of 2015/849 as amended | Status, October 2026 |
|---|---|---|---|
| Cryptocurrency | Exchange and custodian wallet providers became obliged entities | Art 2(1)(3)(g), (h) | Widened to all crypto-asset service providers from 30 December 2024 (Regulation (EU) 2023/1113) |
| Prepaid cards | Anonymous use capped at EUR 150; remote payments over EUR 50 identified | Art 12 | In national law until 10 July 2027 |
| UBO registers | Public access for any member of the public | Art 30(5)(c), 31 | Public access invalid since 22 November 2022; legitimate interest access due by 10 July 2026 |
| PEP functions | National lists of prominent public functions | Art 20a | In national law until 10 July 2027 |
| Luxury goods | Art trade and letting at EUR 10,000 or more | Art 2(1)(3)(d), (i), (j) | In national law; the AMLR keeps both thresholds at EUR 10,000 |
| High risk third countries | Listed enhanced due diligence measures | Art 18a | In national law until 10 July 2027 |
| Registers | Central bank account mechanisms and register interconnection | Art 32a; Art 30(10), 31(9) | In national law; AMLD6 carries both register types forward |
5AMLD still applies in October 2026, through each member state's law. On 10 July 2027 that changes. Regulation (EU) 2024/1624, the AMLR, "shall apply from 10 July 2027" (Article 90), and AMLD6 repeals Directive 2015/849 "with effect from 10 July 2027" (Article 77), which takes every 5AMLD amendment with it. The AMLR applies directly, so firms read one EU text instead of 27 national versions; AMLD6 keeps the registers, supervisors and FIUs. Neither is 6AMLD, the criminal law directive 2018/1673.
The UK is outside the switch. It wrote 5AMLD into the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, in force on 10 January 2020 with the anonymous prepaid card rules from 10 July 2020, and those rules stay in UK law.
Which 5AMLD dates fall in 2026 and 2027?
- 10 July 2026. Member states had to put AMLD6's register access rules into force, among them legitimate interest access (Articles 11, 12, 13 and 15, Article 78).
- Next, 10 July 2027. The AMLR applies and Directive 2015/849, with every 5AMLD change in it, is repealed.
That is why "5AMLD compliance" is the wrong label for a policy. Until 10 July 2027 the policy cites the national law that carries 5AMLD; from that date it cites the AMLR article.
Related terms
- Ultimate beneficial owner. The natural person who owns or controls a customer.
- Travel rule. Originator and beneficiary data sent with a transfer, crypto included.
- Enhanced due diligence. The extra measures for higher risk customers and countries.
- 6AMLD. The 2018 criminal law directive, 2018/1673, on money laundering offenses and penalties.
- MiCA. The EU regulation on markets in crypto assets.
- CASP. A crypto asset service provider licensed under MiCA.
How this entry was checked. Directive (EU) 2018/843 was read as published in OJ L 156 of 19 June 2018, article by article, and the change list follows its Articles 1 and 4 and recital 53. Status lines rest on the Court of Justice's press release 188/22 (22 November 2022, Joined Cases C-37/20 and C-601/20), Regulation (EU) 2023/1113, Directive (EU) 2024/1640 (Articles 10, 12, 77 and 78), Regulation (EU) 2024/1624 (Articles 3 and 90) and the UK's S.I. 2019/1511, all opened on 29 October 2026. The gallery sale is illustrative. Each article number and date passes Ufuk Gürdaş's check, Compliance Specialist, against these texts before the entry is published. Last reviewed: 30 October 2026.
