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Regulatory explainer

5AMLD vs 6AMLD: what actually changed, and what replaces them

5AMLD widened who is regulated; 6AMLD widened who can be prosecuted. A dated, jurisdiction-clear comparison, plus how the 2024 EU AML Package changes both.

Last reviewed: 26 July 2026 ·9 min read
In short

5AMLD (Directive (EU) 2018/843) and 6AMLD (Directive (EU) 2018/1673) changed different things. 5AMLD widened AML scope and transparency, covering crypto, prepaid cards, and beneficial-ownership registers, with a 10 January 2020 deadline. 6AMLD is a criminal-law measure: it harmonised money-laundering offences, added corporate criminal liability and a four-year minimum sentence, applying from 3 June 2021.

  • 5AMLD is Directive (EU) 2018/843; 6AMLD is Directive (EU) 2018/1673. They are separate instruments with different jobs.
  • 5AMLD widened scope and transparency. 6AMLD widened criminal liability.
  • 6AMLD harmonised 22 predicate offences and set a four-year minimum custodial maximum.
  • The UK opted out of 6AMLD, judging its existing law already compliant.
  • Both are superseded by the AMLR single rulebook from 10 July 2027.

At a glance: 5AMLD vs 6AMLD

5AMLD6AMLD
Instrument Directive (EU) 2018/843Directive (EU) 2018/1673
Type of change Scope and transparency of AML obligationsCriminal-law harmonisation
Adopted 30 May 2018Published in the Official Journal 12 November 2018
Transposition deadline 10 January 20203 December 2020
Application from 10 January 20203 June 2021
Primary focus Crypto exchanges and wallets, prepaid cards, art and high-value dealers, public UBO registers, and enhanced due diligence for high-risk third countriesA common EU definition of money laundering, 22 predicate offences, aiding and abetting, and corporate liability
Penalties Administrative, with tightened customer due diligenceMinimum four-year custodial maximum, and corporate criminal liability for legal persons
UK status Implemented, via 2019 amendments to the Money Laundering RegulationsOpted out, as the UK judged existing law under POCA already compliant
Superseded by AMLR (EU) 2024/1624 from 10 July 2027AMLR plus AMLD6-2024 (EU) 2024/1640 from 10 July 2027

Timeline

  1. 30 May 2018
    5AMLD adopted
    The fifth Anti-Money Laundering Directive is adopted.
  2. 10 January 2020
    5AMLD applies
    Transposition deadline and application date for 5AMLD.
  3. 3 December 2020
    6AMLD transposition deadline
    Member states must transpose 6AMLD into national law.
  4. 3 June 2021
    6AMLD applies
    6AMLD applies to obliged entities across transposing member states.
  5. 1 July 2025
    AMLA operational
    The EU Anti-Money Laundering Authority becomes operational in Frankfurt.
  6. 10 July 2027
    AMLR single rulebook applies
    The directly applicable AML Regulation replaces the older directive regime across all 27 member states.

What actually changed

5AMLD widened who is regulated and what they must check. It brought crypto exchanges and custodian wallet providers, prepaid instruments, and art and high-value dealers into scope. It tightened enhanced due diligence for high-risk third countries, and it required public beneficial-ownership registers, a direct response to the Panama Papers.

6AMLD widened who can be prosecuted, for what, and raised the penalties. It adds no new customer due diligence steps. It harmonises a single EU money-laundering definition, fixes 22 predicate offences (adding cybercrime and environmental crime for the first time), and criminalises aiding, abetting, inciting, and attempting. It introduces corporate criminal liability for legal persons, including a failure-to-prevent style exposure, and sets a four-year minimum custodial maximum, up from one year.

Common misconception

6AMLD is 5AMLD but with stricter due diligence.

6AMLD does not touch your onboarding checklist. It is a criminal-law instrument. It changes who can be prosecuted and how hard, not what you collect at onboarding.

The 22 harmonised predicate offences
  1. Participation in an organised criminal group and racketeering
  2. Terrorism
  3. Trafficking in human beings and migrant smuggling
  4. Sexual exploitation
  5. Illicit trafficking in narcotic drugs and psychotropic substances
  6. Illicit arms trafficking
  7. Illicit trafficking in stolen goods
  8. Corruption
  9. Fraud
  10. Counterfeiting of currency
  11. Counterfeiting and piracy of products
  12. Environmental crime
  13. Murder and grievous bodily injury
  14. Kidnapping, illegal restraint, and hostage-taking
  15. Robbery or theft
  16. Smuggling
  17. Tax crimes relating to direct and indirect taxes
  18. Extortion
  19. Forgery
  20. Piracy
  21. Insider dealing and market manipulation
  22. Cybercrime

Who it affects

By entity type
Banks and payment institutions
Core obliged entities under both instruments.
Fintechs
Onboarding and monitoring obligations under 5AMLD-derived rules, and criminal exposure under 6AMLD where transposed.
Crypto-asset service providers
Brought into AML scope by 5AMLD, now a named obliged entity.
Prepaid card issuers
Lower anonymity thresholds under 5AMLD.
Art and high-value goods dealers
In scope above 5AMLD transaction thresholds.
Gambling operators
Obliged entities subject to customer due diligence and monitoring.
By jurisdiction
EU obliged entity
Both 5AMLD and 6AMLD-derived rules apply.
UK-only firm
5AMLD-equivalent rules apply via the UK Money Laundering Regulations. 6AMLD was not transposed.
UK firm active in the EU
Must still meet 6AMLD-derived standards in the member states where it operates.
Jurisdiction scope

The UK opted out of 6AMLD.

WhyHaving left the EU on 31 January 2020, the UK government judged that existing law, chiefly the Proceeds of Crime Act 2002 with sentences up to 14 years, already met or exceeded 6AMLD, so it did not transpose it.
Cross-border catchUK firms operating in or transacting with the EU must still meet 6AMLD-derived standards there. The UK has separately expanded corporate criminal liability on its own track, including the failure-to-prevent-fraud offence and senior-manager attribution reforms.

Penalties and enforcement

6AMLD sets a minimum custodial maximum of four years for money laundering, up from one year under the earlier regime. It introduces corporate criminal liability for legal persons, so a company can be prosecuted where a lack of supervision or control allowed laundering to happen.

Sanctions can extend beyond fines to exclusion from public funding, temporary or permanent bans from commercial activity, and judicial winding-up. The direction of travel is clear: the individual and the organisation are both in scope, and a supervisory failure is itself a source of exposure.

What to do now

  • Map your transaction monitoring and adverse-media screening to all 22 predicate offences, not just the classic financial crimes.
  • Confirm your EU exposure and whether 6AMLD-derived standards apply to any of your operations.
  • Review corporate-liability exposure: could a senior-management failure let a junior employee launder.
  • Confirm adverse-media coverage is broad enough to surface the newer predicates, such as cybercrime and environmental crime.
  • Start AMLR and AMLA readiness now: harmonise customer due diligence, beneficial-ownership data, and entity identification before 10 July 2027.
What supersedes this

From 10 July 2027 the directly applicable AML Regulation, AMLR (EU) 2024/1624, becomes the single rulebook, and AMLD6-2024 (EU) 2024/1640 replaces the transposed pieces of the older directives. The EU Anti-Money Laundering Authority, AMLA, has been operational since 1 July 2025 and takes on direct supervision of selected entities from 2028.

Any 5AMLD-versus-6AMLD explainer that ignores this is already out of date. The obligations described here remain the baseline until 2027, but readiness work should assume the single rulebook is coming.

How orchestration helps

Meeting AML obligations across vendors and jurisdictions, with one audit trail. Zenoo routes and fails over across verification vendors, keeps one audit trail for supervisors, and runs perpetual monitoring so risk refreshes on a trigger rather than a calendar. Your vendors plus Zenoo, with UI freedom via Zenoo Studio. Never a replacement for your existing providers.

Frequently asked questions

Does 6AMLD apply in the UK?

No. The UK opted out of 6AMLD. Having left the EU, the UK judged that existing law, chiefly the Proceeds of Crime Act 2002, already met or exceeded the directive, so it did not transpose it. UK firms operating in the EU must still meet 6AMLD-derived standards there.

When did 6AMLD come into force?

Member states had to transpose 6AMLD by 3 December 2020, and it applied to obliged entities from 3 June 2021.

What are the 22 predicate offences?

6AMLD fixed a harmonised list of 22 categories of criminal activity that count as money-laundering predicates, including corruption, fraud, tax crimes, market manipulation, and, for the first time at EU level, environmental crime and cybercrime.

Is 6AMLD still in force after the 2024 EU AML Package?

For now, yes. The obligations remain the baseline until the AML Regulation single rulebook applies from 10 July 2027, when the directive regime is replaced by directly applicable rules alongside AMLD6-2024.

How is 6AMLD different from 5AMLD?

5AMLD widened who is regulated and what they must check, covering crypto, prepaid cards, and beneficial-ownership registers. 6AMLD is a criminal-law measure that widened who can be prosecuted and raised the penalties. It does not change your onboarding checklist.