Who must comply with the AMLR (obliged entities)

The list of obliged entities is in Article 3 of Regulation (EU) 2024/1624. It is short enough to read in one sitting, and most firms find at least one surprise.

The core groups

• Credit institutions and financial institutions. The definition of financial institution (Article 2(1)) includes investment firms, funds and their managers, life insurers and certain insurance intermediaries, central securities depositories, creditors, and crypto-asset service providers.
• Professionals acting in the course of business, listed in Article 3(3): auditors, external accountants and tax advisors; notaries and lawyers when they take part in certain transactions (buying and selling property or businesses, managing client money or assets, opening accounts, setting up companies or trusts); trust and company service providers; and estate agents.

Sectors worth a second look

Several categories are new to many businesses or carry value thresholds:

• Estate agents are caught for letting only where monthly rent is at least EUR 10,000.
• Dealers in precious metals and stones and in high-value goods, when trading is a regular or principal professional activity.
• Providers of gambling services (subject to the exemptions in Article 4).
• Crowdfunding service providers and intermediaries.
• Art galleries and auction houses, where the transaction or linked transactions reach EUR 10,000.
• Persons dealing in cultural and high-value goods inside free zones and customs warehouses, same threshold.
• Mortgage and consumer credit intermediaries (other than those acting under the responsibility of creditors).
• Investment migration operators.
• Non-financial mixed activity holding companies.
• Football agents and professional football clubs, for specific transaction types. These two groups apply the rules from 10 July 2029 (Article 90); everyone else from 10 July 2027.

Two traps

First, the cash limit. Article 80 sets a EUR 10,000 cap on cash payments for anyone trading goods or providing services, not just obliged entities. A furniture shop is not an obliged entity but still has to respect it, subject to the exceptions in Article 80(4) and any lower national limit.

Second, groups. Article 16 imposes group-wide requirements, so a Maltese subsidiary of a larger group may inherit policies written elsewhere.

Opinion

Do not rely on a sector label. Look at what the business actually does. A law firm that never touches client money or transactions may fall outside Article 3(3)(b), but if tax advice is a principal activity it can still be caught by 3(3)(a). Document the reasoning either way.

See also the AMLR 2027 readiness checklist. In Malta, the FIAU publishes guidance for subject persons, and the European Commission maintains an overview of the EU framework.

What this means for you

If your status is unclear, describe what the business does in the enquiry form. We can give you a written view on scope, by email or after a call.

General information, not legal advice.

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