Nine parts
At a glance: 5AMLD vs 6AMLD
| 5AMLD | 6AMLD | |
|---|---|---|
| Instrument | Directive (EU) 2018/843 | Directive (EU) 2018/1673 |
| Type of change | Scope and transparency of AML obligations | Criminal-law harmonisation |
| Adopted | 30 May 2018 | Published in the Official Journal 12 November 2018 |
| Transposition deadline | 10 January 2020 | 3 December 2020 |
| Application from | 10 January 2020 | 3 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 countries | A common EU definition of money laundering, 22 predicate offences, aiding and abetting, and corporate liability |
| Penalties | Administrative, with tightened customer due diligence | Minimum four-year custodial maximum, and corporate criminal liability for legal persons |
| UK status | Implemented, via 2019 amendments to the Money Laundering Regulations | Opted out, as the UK judged existing law under POCA already compliant |
| Superseded by | AMLR (EU) 2024/1624 from 10 July 2027 | AMLR plus AMLD6-2024 (EU) 2024/1640 from 10 July 2027 |
Timeline
The fifth Anti-Money Laundering Directive is adopted.
Transposition deadline and application date for 5AMLD.
Member states must transpose 6AMLD into national law.
6AMLD applies to obliged entities across transposing member states.
The EU Anti-Money Laundering Authority becomes operational in Frankfurt.
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
- Participation in an organised criminal group and racketeering
- Terrorism
- Trafficking in human beings and migrant smuggling
- Sexual exploitation
- Illicit trafficking in narcotic drugs and psychotropic substances
- Illicit arms trafficking
- Illicit trafficking in stolen goods
- Corruption
- Fraud
- Counterfeiting of currency
- Counterfeiting and piracy of products
- Environmental crime
- Murder and grievous bodily injury
- Kidnapping, illegal restraint, and hostage-taking
- Robbery or theft
- Smuggling
- Tax crimes relating to direct and indirect taxes
- Extortion
- Forgery
- Piracy
- Insider dealing and market manipulation
- Cybercrime
Who it affects
By entity type
By jurisdiction
Jurisdiction scope
Jurisdiction scope
The UK opted out of 6AMLD.
Why: Having 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 catch: UK 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
From reading about it to running it.
You still have to meet these obligations across several vendors and more than one jurisdiction, and keep one record a supervisor can follow. Zenoo builds your compliance workflows across every provider, with each provider connected under your own credentials. Screening, KYB, and KYC flows run through it, risk scoring comes from the Rule Engine, and a person makes every decision. You keep your vendors. Zenoo pulls the checks into one case and keeps the audit trail.