Country-specific guidance Current

Which professional-services firms are obliged entities under EU AML rules

The EU names these professions directly; the practical detail still depends partly on your member state.

The EU's anti-money laundering framework names specific professions as obliged entities with their own due diligence duties. This guide sets out who's covered and what that status actually requires. It is general information, not legal or compliance advice.

Action plan

1 Know that auditors, external accountants, and tax advisers are named obliged entities This isn't an inferred category; the Regulation lists these professions by name.

The EU's Anti-Money Laundering Regulation lists obliged entities to include auditors, external accountants, and tax advisors, and any other natural or legal person, including independent legal professionals such as lawyers, who undertakes to provide material aid, assistance, or advice on tax matters as a principal business or professional activity. Notaries, lawyers, trust or company service providers, and estate agents are separately named for their own qualifying activities.

  • Treat auditors, external accountants, and tax advisers as named obliged entities
  • Check whether other professional activities your firm provides also fall within a named category
  • Don't assume a profession is covered, or excluded, without checking the Regulation's own list

Done when: Your firm's professional activities have been checked directly against the Regulation's list of obliged entities

EUR-Lex: EU Anti-Money Laundering Regulation (EU) 2024/1624, Article 3
2 Apply customer due diligence at the EU's specific trigger points Being an obliged entity means applying due diligence when a defined event happens, not at every client contact.

Once your firm is an obliged entity, the Regulation requires customer due diligence measures at defined points: establishing a business relationship, an occasional transaction of at least EUR 10,000, participating in the creation or transfer of ownership of a legal entity or arrangement, a suspicion of money laundering or terrorist financing, or doubts about previously obtained customer information.

  • Apply due diligence at each of the Regulation's own trigger points
  • Include entity creation, setup, and ownership-transfer involvement as a trigger, not only cash transactions
  • Keep a record of which trigger applied for each due diligence action taken

Done when: Due diligence is applied consistently at the Regulation's own defined trigger points

See requesting identity documents from an individual client
3 Know when this becomes directly applicable, and what governs until then This text is a Regulation, meaning it applies uniformly once it takes effect, but that date hasn't arrived yet.

The Regulation enters into application from 10 July 2027 and, once it does, is binding in its entirety and directly applicable in every member state without national transposition. Until that date, your firm's obligations continue to come from your own member state's currently transposed anti-money laundering law, supervised by whichever national authority that member state has designated for your profession.

  • Treat 10 July 2027 as the date this specific EU-wide text takes direct effect
  • Follow your currently applicable, member-state-transposed AML law until that date
  • Confirm your specific national AML supervisor, since this varies by member state and by profession

Done when: The firm knows both its current national obligation and the date the EU-wide Regulation text takes direct effect

See what's EU-wide and what your member state sets independently