A shopping bag for bread, an ID card for age-restricted purchases — and identity checks when buying a luxury watch. Reports about the EU’s new anti-money laundering rules have prompted questions about whether, from 2027, customers will have to show identification or provide a national identification number every time they shop.
No — the new rules do not introduce a universal identification requirement for everyday shopping. Buying bread or a bottle of wine at a supermarket will not, for that reason alone, become subject to an AML procedure.
Regulation (EU) 2024/1624 of the European Parliament and of the Council — the AMLR — will generally apply from 10 July 2027. It will harmonise customer verification requirements and introduce a EUR 10,000 ceiling on cash payments in the course of business, while allowing lower national limits.
Who will have to verify customers?
The list of obliged entities extends beyond banks. It includes, among others:
- The financial sector: banks, payment institutions and investment firms.
- Accounting and advisory services: auditors, external accountants and tax advisers.
- Legal professionals: notaries, attorneys and other independent legal professionals — when carrying out specified financial and property-related activities.
- Trade in valuable goods: businesses trading in precious metals and stones, and certain luxury goods and cultural goods.
- Real estate: specified professionals acting as intermediaries in purchases, sales and lettings.
- Crypto-assets: crypto-asset service providers.
- Gambling: providers of gambling services, subject to the applicable exemptions.
- Football: professional football clubs and football agents — generally from 10 July 2029.
Some of these sectors are already subject to AML obligations. The reform changes and harmonises the existing system.
The cryptocurrency market: full integration with MiCA and an end to anonymity
The AMLR complements the Markets in Crypto-Assets Regulation (MiCA) and the Regulation on information accompanying transfers of funds and certain crypto-assets (TFR).
Financial institution status: crypto-asset service providers (CASPs), including exchanges and providers holding crypto-assets in custody for customers, are subject to customer identification and verification requirements (KYC). Simply manufacturing hardware or software for self-custody of crypto-assets does not, in itself, make a business such a provider.
The EUR 1,000 threshold: for occasional crypto-asset transactions worth at least EUR 1,000, the provider must apply customer due diligence measures. Customer identification and identity verification are also required below that threshold.
Checks on private wallets: for transfers exceeding EUR 1,000 to or from a self-hosted address, the provider must take adequate measures to assess whether the address is owned or controlled by its customer. This obligation comes from the TFR and does not begin only in 2027. It does not prohibit the use of wallets such as Ledger or Trezor.
The prohibition on anonymity: the AMLR prohibits providers from keeping anonymous crypto-asset accounts or accounts that allow the holder to be anonymised or transactions to be increasingly obscured, including through anonymity-enhancing coins (privacy coins). This is not a general prohibition on private individuals holding such assets.
The art market: identifying the actual buyer
The due diligence threshold: trading in cultural goods and acting as an intermediary in that trade, including through galleries and auction houses, are subject to the relevant obligations for transactions worth at least EUR 10,000. Linked transactions also count.
The beneficial owner: where a company makes the purchase, it may be necessary to identify the natural person who ultimately owns or controls it. Using a company or intermediary does not remove identification requirements.
Free zones: the rules also cover specified activities involving the storage and trading of cultural goods and high-value goods in free zones and customs warehouses.
Real estate: checks on high-value lettings and notaries’ obligations
Checks on luxury rents: AML obligations apply to intermediaries in property lettings where the monthly rent is at least EUR 10,000. The intermediary must apply the required customer and beneficial owner identification measures and assess the transaction’s risk. This is not entirely new in Poland — the same threshold already appears in the Polish AML Act.
Property developers: the activity actually carried out matters. The Regulation refers to developers when, and to the extent that, they act as intermediaries in property purchases, sales or lettings. This should not automatically be equated with every direct sale of their own properties.
Notaries’ obligations: when carrying out activities covered by AML rules, a notary must identify the customer, verify their identity, identify the beneficial owner and understand the transaction’s purpose and nature. Where the circumstances and risk assessment require it, the notary should obtain information about the source of funds and apply additional checks in higher-risk cases. This does not mean conducting a full investigation into the legality of every zloty for every notarial deed.
Suspicious transactions: a notary’s duties may include reporting to the General Inspector of Financial Information (GIIF), Poland’s financial intelligence unit, and refraining from carrying out the transaction as required by law. Customer verification and reporting are not obligations that arise only in 2027.
Football: player transfers, sponsors and investors
From 10 July 2029, the AMLR will generally cover professional football clubs and football agents. For clubs, the obligations will concern transactions with investors, sponsors, agents and other intermediaries, as well as transactions relating to player transfers.
Counterparty verification: clubs will have to identify customers and beneficial owners, assess risks and report suspicious transactions. This does not mean automatically reporting every player transfer to GIIF.
Possible exemptions: Member States may exempt specified clubs from some or all obligations on the basis of demonstrated low risk. For clubs in the top division, an additional condition is annual turnover below EUR 5 million in each of the two preceding calendar years. The exemption is not automatic.
Attorneys and the AMLR — the activities performed are decisive
Whether an attorney is subject to AML obligations depends not only on their professional title, but above all on the activities they perform.
Scenario A: an attorney advising on business transactions
AML obligations may cover:
- Property and business transactions: assistance in planning or carrying out purchases and sales.
- Asset management: managing a customer’s money, securities or other assets, including crypto-assets.
- Accounts: opening or managing bank, savings, securities and crypto-asset accounts.
- Corporate structures: organising contributions and creating, operating or managing companies, trusts, foundations or similar structures.
- Tax advice: providing tax assistance or advice as a principal business or professional activity.
Suspicion of money laundering and the prohibition on tipping off
If, while carrying out activities covered by the AMLR, an attorney suspects or has reasonable grounds to suspect money laundering, they must promptly report the matter to the competent financial intelligence unit — GIIF in Poland — unless an exemption protecting specified information obtained in the course of legal assistance applies.
The prohibition on tipping off also applies: the attorney must not disclose to the customer that a report has been made or that a money laundering analysis is being, or may be, carried out. As a rule, the attorney should refrain from carrying out the suspicious transaction until the report has been made and any further instructions from the competent authority have been followed.
This prohibition already exists under the Polish AML Act — it is not a new rule introduced only in 2027. It does not prevent an attorney from seeking to dissuade a customer from engaging in illegal activity.
Scenario B: an attorney ascertaining a client’s legal position, acting as defence counsel or representing a client in proceedings
Special protection applies to information obtained when:
- Ascertaining the client’s legal position: analysing documents and assessing their rights, obligations and liability.
- Defending or representing the client in judicial proceedings: including advice on instituting or avoiding proceedings, before, during and after those proceedings.
- Acting as defence counsel: particularly in criminal and fiscal criminal cases.
This is not a complete exclusion from the AMLR. The rules provide specific exemptions, particularly from reporting protected information. They do not apply, among other circumstances, where the lawyer participates in money laundering, provides advice for that purpose or knows that the client is seeking advice to facilitate such activity.
What information may a seller request?
For a transaction subject to identification requirements, the information required may include:
- first names and surnames;
- place and full date of birth;
- nationality;
- place of habitual residence;
- where applicable, the national identification number — for example, PESEL in Poland. This is the term used in Article 22(1)(a)(iii) AMLR; national systems differ.
Verification may be based on an identity document or an appropriate electronic identification means. Depending on the circumstances, information about the beneficial owner, the transaction’s purpose and the source of funds may also be needed.
If the required measures cannot be completed, the obliged entity should, as a rule, refuse to carry out the transaction.
Financial thresholds and limits at a glance
| Transaction or goods | Financial threshold | Verification or obligation |
|---|---|---|
| Occasional cash transaction with an obliged entity | From EUR 3,000 | Generally, customer identification and identity verification. |
| Occasional transaction with an obliged entity — including payment by card or bank transfer | From EUR 10,000 | Identification and verification of the customer and beneficial owner, establishing the purpose and nature of the transaction and, where necessary, the source of funds. |
| Cash payment for goods or services in the course of business | Up to EUR 10,000 | The EU maximum; lower national limits may apply. Showing identification does not permit payment above the limit. |
| Trade in cultural goods, including works of art | From EUR 10,000 | Identification and verification of the customer and beneficial owner, establishing the purpose and nature of the transaction and, where necessary, the source of funds. |
| Jewellery, goldsmiths’ and silversmiths’ wares, clocks and watches | Above EUR 10,000 | Identification and verification of the customer and beneficial owner, establishing the purpose and nature of the transaction and, where necessary, the source of funds. |
| Motor vehicles | Above EUR 250,000 | Identification and verification of the customer and beneficial owner, establishing the purpose and nature of the transaction and, where necessary, the source of funds. Transactions covered by Article 74 AMLR must also be reported to GIIF. |
| Certain aircraft and watercraft | Above EUR 7,500,000 | Identification and verification of the customer and beneficial owner, establishing the purpose and nature of the transaction and, where necessary, the source of funds. Transactions covered by Article 74 AMLR must also be reported to GIIF. |
| Occasional crypto-asset transaction with a service provider | From EUR 1,000 | Identification and verification of the customer and beneficial owner, establishing the purpose and nature of the transaction and applying the other required measures. Customer identification and verification are also required below the threshold. |
| Intermediation in property lettings | Monthly rent from EUR 10,000 | Identification and verification of the customer and beneficial owner, establishing the purpose and nature of the business relationship and, where necessary, the source of funds. |
Linked transactions count towards the thresholds. Splitting a payment into several parts does not remove the obligations. Suspicion of money laundering may require procedures to be applied regardless of the amount.
Sanctions and penalties
Directive (EU) 2024/1640, which accompanies the AMLR, provides for a differentiated system of sanctions.
Credit institutions and financial institutions: for legal persons, the statutory maximum pecuniary sanction must be at least EUR 10 million or 10% of annual turnover, whichever is higher. For natural persons under this regime, the maximum must be at least EUR 5 million.
These are not uniform limits for all businesses. The detailed rules on liability must be considered together with the national legislation implementing the Directive.
Frequently asked questions
Will I have to show ID or provide a national identification number every time I shop?
No. The obligation depends on whether the seller and the transaction are covered by AML rules. National identification numbers are required only where applicable; there is no single EU-wide equivalent of Poland’s PESEL number.
Does paying by card remove identification requirements?
No. For specified transactions, the obligations apply regardless of the payment method.
Can a payment be split to avoid checks?
Linked transactions are considered together. Simply dividing a payment into instalments does not remove the obligations.
Can I pay cash above the limit after showing identification?
No. Customer identification does not override the cash payment restriction.
Does the EU cash limit cover private sales between individuals?
It does not cover payments between natural persons who are not acting in a professional capacity.
What are the new rules intended to achieve?
The AMLR aims to make it harder to introduce the proceeds of crime into the legitimate economy and to counter terrorist financing. Common rules are intended to reduce the exploitation of differences between Member States’ systems.
Money laundering does not have to take place solely through bank accounts. Gold, works of art and luxury items may themselves serve as a currency in money laundering schemes. This is why the obligations include establishing who is actually behind a transaction, on whose behalf they are acting and — where the circumstances require it — where the funds come from.
Do you remember The Accountant with Ben Affleck?
Christian Wolff, a brilliant accountant working for criminal organisations, receives payment in gold bars and works of art, among other things. In his world, a painting by a famous artist is more than decoration — it can also be a fee.
Investigators from the US Treasury Department try to establish his identity. Accepting valuable objects instead of ordinary bank transfers illustrates how difficult such settlements can be to trace: assets change hands even though no payment reaches a bank account.
It is a cinematic illustration of the problem AML rules seek to address: behind a valuable object there may be a financial history that a receipt alone will not reveal.
Financial security and the limits of state scrutiny
The new rules also raise questions about the limits of state interference with privacy, the extent of data collection and the protection of professional secrecy, including lawyer–client confidentiality. Obligations to identify customers and report suspicious transactions require effective crime prevention to be reconciled with the right to confidential legal assistance. The key issue will be whether the application of the rules remains proportionate to the risk and avoids excessive scrutiny of lawful transactions.