Policy Briefing — EU Sixth AML Directive Deadline
EU Member States reached the transposition deadline for the Sixth Anti-Money Laundering Directive, expanding predicate offences and liability requirements for AML programs.
Executive briefing: December 3, 2020 marked the European Union’s deadline for Member States to transpose Directive (EU) 2018/1673 on combating money laundering by criminal law (6AMLD). Financial institutions and obliged entities must confirm that national implementations now cover the directive’s enlarged offence list, corporate liability provisions, and tougher sanction framework.
Immediate compliance priorities
- Legal gap assessment. Compare local AML statutes and regulations with 6AMLD articles to verify the inclusion of cybercrime, environmental crime, and tax offences as predicates.
- Liability coverage. Ensure policies and governance extend to aiding, abetting, and attempting money laundering, recognising potential criminal liability for legal persons.
- Sanction readiness. Update disciplinary matrices and escalation routes to reflect heightened imprisonment thresholds and €5 million corporate fines.
Control alignment
- Risk typologies. Refresh transaction monitoring scenarios and KYC questionnaires to capture newly listed predicate offences, especially environmental and cyber-enabled crimes.
- Training. Deliver jurisdiction-specific AML training outlining national transposition nuances and expanded liability expectations for senior management.
- Third-party oversight. Re-evaluate correspondent and fintech partner controls to ensure contractual clauses address 6AMLD obligations.
Enablement moves
- Create centralised trackers of Member State transposition measures to support cross-border compliance attestations.
- Coordinate with legal counsel to document reliance on EU-wide typology guidance from Europol and the European Banking Authority.
- Enhance case management systems to capture participation, attempt, and facilitation scenarios for suspicious activity reporting.
Sources
- Directive (EU) 2018/1673 on combating money laundering by criminal law
- European Commission announcement on the adoption of 6AMLD
Zeph Tech equips AML teams with offence-mapping worksheets, liability control checklists, and multi-jurisdictional training packs for 6AMLD compliance.
Follow-up: By 2022 the Commission confirmed full transposition, and the 2024 AML package’s new directive will ultimately replace Directive (EU) 2018/1673 once national laws adopt the expanded criminal offences.