Picture a company director (illustrative) who takes €200,000 from the company and moves it through a personal account, then through a relative's account. The taking is embezzlement. The moves are laundering. Under Article 3(5) of the 6AMLD, the director can be punished for both, because the EU's common definition of money laundering covers people who launder the proceeds of their own crime.
What is 6AMLD, and what is its scope?
6AMLD is Directive (EU) 2018/1673 "on combating money laundering by criminal law", adopted on 23 October 2018 and published in the Official Journal on 12 November 2018 (L 284). Article 1 sets its scope: "minimum rules concerning the definition of criminal offences and sanctions" in the area of money laundering.
A directive binds member states, not firms. Each state writes these rules into its own criminal law, so the offense a prosecutor charges is the national one. The directive decides what counts as laundering, which crimes feed it, how high the maximum sentence must at least go, when a company is liable and which state may prosecute.
That makes it a criminal law act, not a customer checks act. The previous AML directives, the fourth (Directive (EU) 2015/849) as amended by the fifth, are the preventive ones: they set customer due diligence (CDD), enhanced due diligence (EDD) and reporting to financial intelligence units (FIUs).
Is 6AMLD the same as AMLD6?
No. The name is written many ways (6AMLD, AMLD 6, 6 MLD, the 6th AML directive), and two different acts carry a "sixth directive" label. Each EU duty comes from one named act:
- Directive (EU) 2018/1673, the 6AMLD. The criminal offense, the predicate list and the penalties.
- Directive (EU) 2015/849, the 4AMLD as amended by the 5AMLD. The checks a firm runs today, until 10 July 2027.
- Regulation (EU) 2024/1624, the AMLR. The checks from 10 July 2027 for most obliged entities (Article 90), directly applicable anti money laundering rules for firms.
- Directive (EU) 2024/1640, the AMLD6. Supervisors, FIUs and beneficial ownership registers; transposed by 10 July 2027, with the register access articles due by 10 July 2026 (Article 78).
- Regulation (EU) 2024/1620, AMLA. The new EU authority, which picks 40 obliged entities in 2027 for the direct supervision it begins in 2028.
What does the 6AMLD require member states to do?
Table 1. Directive (EU) 2018/1673, article by article (as amended, October 2026).
| Article | What it requires | Member state minimum | Note |
|---|---|---|---|
| 2 Definitions | A list of predicate offense categories | All 23 categories count as criminal activity | Point (w), violation of Union restrictive measures, added by Directive (EU) 2024/1226, Article 18 |
| 3 Offenses | Conversion or transfer, concealment, and acquisition, possession or use of criminal property | All three punished when intentional | 3(5): self laundering, for conversion, transfer or concealment by the person who committed the crime |
| 4 Participation | Aiding and abetting, inciting and attempting | Punished as offenses | Applies to Article 3(1) and (5) |
| 5 Natural persons | Effective, proportionate and dissuasive penalties | A maximum prison term of at least four years | A ceiling of at least four years, not a minimum sentence |
| 6 Aggravation | Circumstances that raise the penalty | A criminal organization; an offender who is an obliged entity | 6(2) lets states add property of considerable value |
| 7 and 8 Companies | Liability of legal persons and the sanctions on them | Fines, criminal or not; other measures optional | Explained in the next section |
| 9 Confiscation | Freezing and confiscating proceeds and instruments | Under Directive 2014/42/EU | None |
| 10 Jurisdiction | Which state may prosecute | Offenses on its territory or by its nationals | Cooperation when several states can |
| 11 Investigation | Tools used against organized crime | Available to investigators | None |
| 12 Framework Decision | Supersedes parts of Framework Decision 2001/500/JHA | For the bound member states | Denmark stays on the framework decision |
Article 5(2) sets the maximum term a court must be able to impose, at least four years; some vendor summaries misread it as a four year minimum. The list in Article 2 has 23 categories since Directive (EU) 2024/1226, whose own transposition deadline was 20 May 2025. Fraud and tax crimes are on it, and Article 2(1) also counts any offense punishable by a maximum of more than one year in prison, so a predicate offense can be almost any serious crime.
When is a company liable under the 6AMLD?
Article 7 gives two routes. Under 7(1), a company is liable for laundering committed for its benefit by a person in a leading position: someone with a power of representation, an authority to take decisions or an authority to exercise control. Under 7(2), it is liable when "lack of supervision or control" by such a person made the offense possible, committed for its benefit by someone under its authority.
Picture a payments firm (illustrative) whose branch manager ignores repeated alerts on one employee's customers while that employee moves criminal funds for fee income. No director laundered anything, yet the firm can be liable under 7(2), because the missing supervision made the offense possible. Article 8 then requires fines, criminal or not, and allows other sanctions such as exclusion from public benefits, a ban on commercial activity, judicial supervision or winding up.
The two "sixth directives" bind different people. Directive (EU) 2018/1673 reaches a firm only as a defendant, through Article 7; Directive (EU) 2024/1640 organizes supervisors, FIUs and registers. A policy that cites "6AMLD" for customer due diligence cites the wrong act either way, since those checks come from Directive (EU) 2015/849 until 10 July 2027 and from the AMLR after it.
complead, formerly Sanction Scanner, records the owner, reason, decision and timestamp on every clearance and escalation for compliance officers, so the record shows what the reviewer saw, what was decided and why.
What does the 6AMLD mean for a regulated firm?
The directive adds no customer check, but it changes how a firm describes the crime it reports on:
- Use the 23 categories as the offense taxonomy. Policies, training and adverse media screening can map each hit to one category.
- Train staff on self laundering. A customer who moves the proceeds of a crime they committed is laundering too.
- Know Article 6(1)(b). An obliged entity that launders in the course of its professional activities faces an aggravated offense.
- Read the national transposing law. Penalties and company liability differ by member state above the floor.
- Keep CDD on the right act. Directive (EU) 2015/849 until 10 July 2027, then the AMLR.
Where the directive stands in October 2026
- 24 April 2024. Directive (EU) 2024/1226 added the violation of Union restrictive measures as the 23rd category.
- 20 May 2025. Its transposition deadline passed.
- 10 July 2026. The AMLD6 register access articles fell due, a step in the other act.
- 10 July 2027. The AMLR applies and Directive (EU) 2015/849 is repealed; the 6AMLD stays in force.
Back to the director: the laundering charge for moving the €200,000 now rests on an EU wide minimum in every bound member state. The bank's duty to spot those transfers still comes from the other acts.
Related terms
- Money laundering. Hiding the criminal origin of money or property.
- Predicate offense. The crime that produced the money, such as fraud.
- Anti money laundering. The laws and controls that stop criminal money entering the financial system.
- Financial crime. Crimes that involve money or financial services, laundering among them.
- 5AMLD. The fifth directive, Directive (EU) 2018/843, which amended the fourth.
How this entry was checked. On 29 October 2026 the entry was read against the Official Journal texts of Directive (EU) 2018/1673, Directive (EU) 2024/1226 (Articles 18 and 20), Directive (EU) 2024/1640 (Article 78), Regulation (EU) 2024/1624 (Article 90) and AMLA's published timeline. Where other sources call two acts the sixth AML directive, this entry names each by its number, and the definition rests on Articles 1 to 3 of the 2018 directive. The director and the payments firm are illustrative. The author, Melis Alparslan (Regional Sales Manager at complead), drafted the entry; the reviewer, Ufuk Gürdaş, Compliance Specialist, traced every article number and deadline to the Official Journal. Last reviewed: 30 October 2026.
