EU AML Regulation 2027 (AMLR): what changes for KYB

On 10 July 2027, the EU Anti-Money Laundering Regulation (AMLR) replaces 27 national transpositions with one rulebook that applies word for word in every member state (Article 90, Regulation (EU) 2024/1624). For KYB, six things change: the beneficial ownership threshold becomes 25% or more, control is tested in parallel with ownership, the central register becomes a mandatory cross-check, sanctions screening reaches whoever controls the company, review cycles get a legal maximum and automated decisions need meaningful human intervention.

The threshold change looks small and is not. Across the ownership structures built on Dotfile over the past year, about 1 in 85 had a person holding exactly 25%: not a beneficial owner by ownership today, one on 10 July 2027.

What is the AMLR?

The AMLR is Regulation (EU) 2024/1624, the centre of the EU's anti-money laundering package adopted in 2024. Because it is a regulation and not a directive, it applies directly: no national law transposes it, and no member state can add its own reading of the beneficial ownership test. It was published in the Official Journal on 19 June 2024 and applies from 10 July 2027, except for football agents and professional football clubs, which follow on 10 July 2029 (Article 90).

It comes with two other texts:

What changes for KYB under the AMLR?

1. The beneficial ownership threshold becomes "25% or more"

Today the rule is an indication: "a shareholding of 25 % plus one share or an ownership interest of more than 25 %" (Article 3(6)(a)(i), Directive (EU) 2015/849), transposed with national variations. The AMLR makes it a definition: "direct or indirect ownership of 25 % or more of the shares or voting rights or other ownership interest" (Article 52(1)). A person at exactly 25% changes status overnight.

The same article fixes the arithmetic for indirect stakes: multiply along each chain, add across chains and take "all shareholdings on every level of ownership" into account. Our AMLR beneficial ownership guide works through the calculation.

The threshold can go lower for some entities. By 10 July 2029, the Commission must assess whether categories of corporate entities identified as higher risk need a lower threshold, set "at a maximum of 15 %" (Article 52(2)).

2. Control is tested in parallel, not as a fallback

Control via other means "shall be identified independently of and in parallel to" ownership (Article 51), so a 10% shareholder who appoints the board is a beneficial owner, and when nobody qualifies you record it and verify all senior managing officials (Article 22(2)). The AMLR beneficial ownership guide covers the control test in detail.

3. The central register becomes a mandatory cross-check

You verify beneficial owners with documents and independent sources, then consult the central register on top (Article 22(7)); recital 54 says it "should not be the obliged entity's primary source for verification". Discrepancies are reported within 14 calendar days (Article 24), as the UBO verification process explains step by step.

4. The sanctions check reaches control

Customer due diligence now includes checking whether sanctioned persons "control the legal entity or have more than 50 % of the proprietary rights" (Article 20(1)(d)). A screening that stops at the company name and its directors misses it.

5. Reviews get a legal maximum

The period between two updates of customer information "shall not in any case exceed" one year for higher-risk customers and five years for the others (Article 26(2)). Today each member state sets its own cycle. How to run them: ongoing monitoring and automated periodic reviews.

6. Automated decisions need a person

You may decide through automated processes or AI systems, provided the data comes from due diligence, every decision to enter, refuse or maintain a relationship, or to raise or lower due diligence, "is subject to meaningful human intervention", and the customer can obtain an explanation and challenge it (Article 76(5)). The decision on the customer's risk profile and the decision to enter the relationship are among the tasks that can never be outsourced (Article 18(3)). What regulators say about AI in compliance covers the rest of the AI picture.

A worked example: four shareholders at 25%

Take a fictional Belgian company, Atlas Ventures SRL, owned by four people with 25% each, and a general manager, Marc, who holds no shares.

Same company, same register extract, a different file. Every customer with a 25% holder needs a new beneficial owner analysis at its next review after the date. 1 in 85 sounds rare until you multiply it by your book.

Based on ownership structures built on Dotfile over the past year, with person-level stakes computed across chains; aggregates only.

What is AMLA's role in KYB?

AMLA, the EU Anti-Money Laundering Authority, writes the detailed rules: on 1 October 2026 it submitted its final draft standards on customer due diligence (Article 28(1)) and on business relationships, occasional and linked transactions (Article 19(9)) to the Commission. From 2028 it will also supervise some firms directly, up to 40 in its first selection; who and when is in our AMLA guide, and every date is in the AML regulatory calendar.

What should a KYB team change before 10 July 2027?

1. Recompute every beneficial owner at "25% or more", starting with structures that have a holder at exactly 25%.
2. Record the "no beneficial owner" case explicitly, with all senior managing officials verified.
3. Make the register check a step with a 14-day clock on discrepancies.
4. Screen controllers, not just names, for the Article 20(1)(d) sanctions test.
5. Set review cycles of at most one and five years, with event triggers.
6. Document where a person intervenes in every automated decision.

Frequently asked questions

When does the AMLR apply?

From 10 July 2027 for all obliged entities, and from 10 July 2029 for football agents and professional football clubs (Article 90).

Does the AMLR change the 25% beneficial ownership threshold?

Yes, from "more than 25%" to "25% or more". A person at exactly 25% becomes a beneficial owner.

What is the EU AML Regulation?

Regulation (EU) 2024/1624, the single rulebook for anti-money laundering duties of banks, payment firms, crypto-asset service providers and other obliged entities in the EU. It applies directly from 10 July 2027.

Does the AMLR replace national AML laws?

For obliged entities' duties, yes: the regulation applies directly. National law still organises supervisors, FIUs and registers under AMLD6.

Who is an obliged entity under the AMLR?

Credit and financial institutions, including crypto-asset service providers, plus designated professions such as auditors, notaries, lawyers, estate agents, trust and company service providers and, new, crowdfunding platforms and mortgage and consumer credit intermediaries (Article 3).

Where Dotfile fits

Dotfile's ownership unravelling computes each person's total stake across chains, direct and indirect, so a holder at exactly 25% shows up as a number rather than a guess, and the control view puts voting rights and board positions next to shareholdings. Periodic review sets a review period per risk level, and Data Lineage records the source of every value you will need when a supervisor asks. For the full process, read what is KYB.