EU Anti-Money Laundering Rules Will Reach Luxury Dealers and Football Clubs

From 10 July 2027, the EU’s Anti-Money Laundering Regulation will apply directly across all 27 member states. Businesses will need to prepare for new reporting and monitoring obligations while some of the detailed standards are still being finalised.

By Piotr Jagodziński. The Polish original was published on 3 November 2026.

Since 1991, the European Union has fought money laundering through directives that each member state implemented in its own way. From 10 July 2027, key obligations will move into the directly applicable Anti-Money Laundering Regulation (AMLR). Companies have less time to prepare than the date suggests.

One regulation across 27 countries

The same text will apply from Lisbon to Warsaw and Helsinki. The regulation has 90 articles and six annexes, with further detail to follow. The Frankfurt-based Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) expects 40 additional measures, comprising 13 regulatory technical standards, six implementing technical standards and 21 guidelines. It published the final drafts of the first standards, including requirements on the customer data firms must collect, on 30 September 2026.

Luxury goods, crowdfunding and professional football

The regulation extends obligations to independent credit intermediaries, crowdfunding platforms and professional dealers in luxury goods. It covers cars worth more than €250,000, yachts and aircraft above €7.5 million, and watches and jewellery above €10,000.

From July 2029, the rules will also cover football agents and licensed professional clubs in dealings with investors, sponsors and intermediaries and in player transfers. In Poland, that could include the entire Ekstraklasa. Member states can exempt top-flight clubs only if their turnover was below €5 million (about PLN 22 million) in each of the previous two years. Distributions from Ekstraklasa alone averaged nearly PLN 17 million per club for the 2025/26 season, and those payments account for only part of club revenue.

A dealer who buys a used watch or a gold bar from a customer for €20,000 must also verify the seller, because the regulation treats a supplier of goods as a customer. A dealership that sells a €300,000 car for private use must report the transaction to Poland’s General Inspector of Financial Information (GIIF), even if it sees no grounds for suspicion. The regulation also treats siblings of senior politically exposed persons, such as ministers, as family members, extending the definition used under current Polish law.

From 10 July 2027, cash payments for goods and services across the EU will be capped at €10,000 (about PLN 44,000), including when a payment is split into linked transactions. Poland currently has no such limit on sales to consumers. The cap excludes payments between individuals acting privately and cash deposits at banks. Member states may set lower limits.

Customer checks continue throughout the relationship

Collecting data at onboarding begins a continuing process. Firms must understand the customer, build a risk profile, monitor transactions and activity, detect changes and update their assessment. For occasional transactions, they must also consider whether repeated contacts or transactions indicate an ongoing business relationship.

Firms must establish who actually controls a company and what powers they hold. They must calculate indirect ownership by multiplying stakes along each chain and adding the results. The same approach will apply to sanctions screening, including regular checks for control by listed persons or combined holdings above 50%.

Technology can support these checks, alongside staff and reliable data. AMLA describes itself as a “data-driven regulator”.

Compliance costs and implementation

AML has often been an onboarding check handled by compliance teams. It will become a continuous process embedded in sales, customer service, data and systems. Implementation will continue beyond July 2027.

LexisNexis Risk Solutions estimates that financial institutions across Europe, the Middle East and Africa spend about $85 billion a year on financial crime compliance. Costs rose at 98% of institutions in 2023, mainly because of labour costs. Implementation often requires technology changes as well as new procedures. Under the sixth Anti-Money Laundering Directive (AMLD6), Poland must raise the maximum penalty for financial institutions from €5 million to at least €10 million, or 10% of turnover.

Customers will typically face more questions, including about all their nationalities, their occupation or business, the purpose and expected scale of the relationship, and the source and intended use of funds. Companies must decide when to ask each question, how to verify the answer and who makes the decision. Poorly designed processes can produce excessive alerts and delay transactions, while well-designed ones should be barely visible to customers.

The more customers, products, data and systems an organisation has, the earlier it needs to move from analysis to implementation. Banks face the hardest changes because even a small procedural adjustment can affect several systems and stages of customer service. For companies outside finance, challenges are more likely to involve new duties such as assessing the risk of breaching or circumventing sanctions.

Companies should first determine whether and to what extent the AMLR applies to them. They can then review gaps in customer data, ownership structures and sanctions controls, cash acceptance, and the systems and staff needed for ongoing monitoring. That review can inform a budget and timetable while AMLA completes its standards.

Sources

• Regulation (EU) 2024/1624 (AMLR).
• AMLA roundtable presentation on 40 measures, including 13 regulatory technical standards, six implementing technical standards and 21 guidelines.
• AMLA final draft regulatory technical standards on customer due diligence, 30 September 2026.
• AMLA overview of regulatory instruments, including draft guidelines on ongoing monitoring.
• GazetaPrawna.pl on cash payment limits in Poland.
• AMLR, Article 5, on exemptions for clubs with turnover below €5 million.
• Ekstraklasa SA, 2025/26 club distributions, 30 June 2026. Over PLN 301.1 million went to 18 clubs.
• LexisNexis Risk Solutions, True Cost of Financial Crime Compliance Study – EMEA, conducted by Forrester Consulting, 6 March 2024. Annual costs were $85 billion and rose at 98% of institutions in 2023, mainly because of labour costs.