AMLD5 and AMLD6 — the EU's Fifth and Sixth Money Laundering Directives — are two separate instruments that are routinely conflated. On top of that, the 2024 AML Package contains another AMLD6 (Directive (EU) 2024/1640). This article walks through all three: what each binds, who it applies to, and when. It then sets the EU framework next to Turkey's MASAK regime and the UK MLR 2017.
Three Directives, Three Scopes
| Directive | Number | Adopted | Transposition | Subject |
|---|---|---|---|---|
| AMLD5 | Directive (EU) 2018/843 | May 2018 | January 2020 | CDD expansion, VASPs, BO register |
| AMLD6 (old) | Directive (EU) 2018/1673 | November 2018 | December 2020 | Predicate offences, criminal liability |
| AMLD6 (new, 2024 Package) | Directive (EU) 2024/1640 | June 2024 | 10 July 2027 | FIU, supervision, penalty regime |
The first two remain in force today. The new AMLD6 (2024/1640) becomes applicable on 10 July 2027 and repeals the old AMLD6.
What AMLD5 (2018/843) Brought
AMLD5 was adopted on 30 May 2018 and transposed by Member States by 10 January 2020. Five core changes:
1. VASPs Into Scope
The biggest shift: AMLD5 brought virtual asset service providers (VASPs) into the EU AML framework for the first time. Article 2(1)(g) and (h) defined two categories:
- Providers engaged in exchange services between virtual currencies and fiat currencies (crypto exchanges).
- Custodian wallet providers.
Such providers had to register or obtain authorisation in each Member State, perform customer due diligence (CDD), file suspicious transaction reports and conduct risk assessments.
2. Expanded PEP Definition
Member States must maintain national PEP lists (Article 20a). Domestic PEPs — those from a Member State's own jurisdiction — are now subject to the same CDD level as foreign PEPs. For more on PEP screening see our What is a PEP article.
3. Beneficial Ownership Registers
Member States had to establish central beneficial ownership registers for legal entities (Article 30). Access to obliged entities was guaranteed. This was later restricted by the ECJ Sovim ruling (November 2022) for general public access, but obliged entity and competent authority access continues.
4. Lower Prepaid Card Thresholds
The CDD exemption threshold for non-named prepaid cards dropped from €250 to €150. Full CDD became mandatory for online purchases.
5. High-Risk Third Country Rules
The Commission maintains a "high-risk third country" list; customers and counterparties from those jurisdictions receive enhanced due diligence (EDD).
What AMLD6 (Old, 2018/1673) Brought
AMLD6 — adopted 23 October 2018 — focused on a narrower subject: the criminal-law dimension of money laundering.
1. Harmonisation of Predicate Offences
Member States had divergent lists of "predicate offences" (the underlying crime that gives rise to laundered proceeds). AMLD6 defined 22 categories: fraud, smuggling, terrorism financing, cybercrime, environmental crime and so on.
2. Minimum Maximum Sentence
Member States must impose a maximum penalty of at least 4 years' imprisonment for money laundering (i.e. define an offence category whose upper sentence range is at least 4 years).
3. Corporate Criminal Liability
Corporate criminal liability for money laundering was clarified. Legal persons can be penalised for offences enabled by inadequate management oversight.
4. Aiding, Abetting, Attempt
These were explicitly criminalised.
Old AMLD6 was transposed by 3 December 2020. In practice this directive did not impose new direct operational obligations on obliged entities — it was more a national criminal law alignment exercise.
AMLD5 vs AMLD6 (Old) Side-by-Side
| Topic | AMLD5 (2018/843) | AMLD6 (2018/1673) |
|---|---|---|
| Adopted | May 2018 | November 2018 |
| Transposed | January 2020 | December 2020 |
| Primary target | CDD + obliged entity | Criminal liability |
| VASP coverage | Yes, first time | No |
| BO register | Yes, central | No |
| Predicate offences | No | Yes, 22 categories |
| Corporate liability | No | Yes, clarified |
| Minimum sentence | No | 4-year maximum floor |
The New AMLD6 in the 2024 AML Package (2024/1640)
The 2024 AML Package, published in the Official Journal on 10 July 2024, consists of three parts: AMLR (2024/1624), AMLD6-new (2024/1640), AMLAR (2024/1620). The new AMLD6 repeals the old AMLD6 and covers a different scope:
- FIU empowerment: powers and operational rules for national Financial Intelligence Units.
- Supervision: duties, powers and cooperation rules for national competent authorities (including coordination with AMLA).
- Penalty regime: administrative fines, sanctions for natural and legal persons.
Important note: as of May 2026 the term "AMLD6" can refer to either directive depending on context. Most practitioners still mean the old one (2018/1673); EU regulation followers increasingly mean the new one (2024/1640). In professional communication always include the directive number.
Comparison With TR and UK
| Topic | EU AMLD5/6 | Turkey MASAK | UK MLR 2017 |
|---|---|---|---|
| Primary law | AMLD5 + AMLD6 (old) | Law No. 5549 + MASAK communiqués | MLR 2017 |
| VASP scope | Yes (AMLD5) | KVHS regulation | Yes (FCA registration) |
| BO register | Central, per Member State | MERSİS system | Companies House PSC register |
| PEP definition | Broad, domestic + foreign | MASAK communiqués | MLR 2017 + FCA guidance |
| Screening obligation | Ongoing CDD | MASAK communiqués | MLR 2017 |
| Predicate offences | AMLD6 22 categories | Within Turkish Penal Code | Proceeds of Crime Act |
| Minimum sentence | 4-year maximum floor | TCK supplementary | POCA + MLR |
For the TR side see our MASAK compliance guide. For the UK side see our UK MLR 2017 explained article.
Practical Impact for an Obliged Entity
Today — May 2026 — operational compliance load for an EU obliged entity (bank, EMI, PSP, CASP) still rests on AMLD5. Old AMLD6 sits more in the criminal-law layer and does not directly add operational tasks.
Obligations unchanged until 2027:
- Customer due diligence (CDD) — risk-based.
- Ongoing monitoring (sanctions, PEP, adverse media).
- Suspicious transaction reporting (to the FIU).
- Beneficial ownership register queries.
From 2027, AMLR + AMLD6-new take effect. AMLR's direct applicability brings tighter and more homogeneous rules EU-wide. Practical advice: start the 2027 preparation now — especially the cash threshold (€10k), beneficial owner verification and enhanced due diligence processes, all reviewed against the AMLR text.
Frequently Asked Questions
When someone says "AMLD6," how do I know which directive they mean?
As of May 2026, look at the context: if the topic is criminal liability or predicate offences, it is the old one (2018/1673); if it is FIUs, supervision or AMLA, it is the new one (2024/1640). In professional communication always include the directive number: "AMLD6 (2018/1673)" or "AMLD6 (2024/1640)."
What is AMLD5's most lasting impact?
Bringing VASPs into EU AML scope. Pre-2020, crypto exchanges operated EU-wide without AML obligations; AMLD5 closed that gap. MiCA + TFR later layered a much more comprehensive crypto regime on top, but AMLD5 was the first step.
Did old AMLD6 impose new operational tasks on obliged entities?
Not really. The directive's primary aim was harmonisation of national criminal law. For obliged entities the practical impact was that clarified corporate liability drew board-level attention to AML governance — but day-to-day CDD/STR flows did not change.
Does AMLR (2024/1624) also repeal AMLD5?
Yes. When AMLR becomes applicable on 10 July 2027, AMLD5 (2018/843) and AMLD4 are repealed. AMLD5's CDD, VASP scope and BO register provisions are absorbed into AMLR (in expanded and homogenised form).
Is Turkey's MASAK framework fully aligned with AMLD5?
Structurally largely aligned — Law No. 5549 and MASAK communiqués parallel obliged entity definition, CDD and STR obligations. Differences: BO register sits in MERSİS (in the EU each Member State runs its own); VASP coverage in TR is embedded in the KVHS regulation (in the EU it is in AMLD5 + MiCA). For detailed Turkey analysis see our MASAK compliance guide.
How Legichain Helps with AMLD Compliance
AMLD5's CDD, PEP/sanctions screening, adverse media and ongoing monitoring obligations — soon under the AMLR umbrella — are Legichain's primary solution area. The Legichain AML screening API offers EU consolidated lists (Council Regulation lists, national sanctions lists) alongside OFAC and UN lists, with real-time synchronisation so every screen is current. Match-grouping reduces false positives on PEP and adverse media hits by 80-90%. With AMLR 2027 in view, our infrastructure is built for the tighter homogeneity of a directly applicable rulebook.