The 6th Anti-Money Laundering Directive and crypto: new requirements for banks
With the EU AMLA package and the 6th Anti-Money Laundering Directive, AML rules are being harmonised across Europe. What does this concretely mean for banks with crypto exposure?
In June 2024 the EU AMLA package (Anti-Money Laundering Authority) entered into force — consisting of the regulation on the new EU AML authority, a new AML regulation (AMLR), and Directive (EU) 2024/1640, commonly referred to as the 6th Anti-Money Laundering Directive (6AMLD). German transposition into the Money Laundering Act has a deadline of July 2027 — but preparations should already be well under way.
What's new?
6AMLD brings three changes that are particularly relevant for banks with crypto touchpoints:
1. A directly applicable EU regulation
Unlike before, the AML regulation (AMLR) is a directly applicable EU law that does not need to be transposed into national law. This reduces the fragmentation of AML obligations that previously varied between member states.
2. Cash threshold lowered to €10,000
For cash transactions, an EU-wide ceiling of €10,000 applies. This affects crypto indirectly: physical meetings for BTC purchases ("OTC cash trades") become mandatory documentation events under AML law.
3. Enhanced due diligence for self-custodied wallets
For transfers between a CASP and a customer's self-custodied wallet above €1,000, enhanced KYC checks are mandatory. Banks acting as payment partners for crypto onramps must verify that the wallet address actually belongs to their customer (so-called address verification).
What does this mean for banks?
Banks with crypto customers (e.g. as a partner bank for onramps or as custodian for institutional clients) face a double challenge:
- More depth: Due-diligence duties go beyond pure customer identification. Counterparty analyses and source-of-funds checks become standard processes.
- More breadth: Fiat credits from crypto transactions (e.g. BTC sales) are also subject to enhanced review duties.
A quote from one of our conversations with AML teams:
"We can no longer say 'that's crypto, we don't look at it'. 6AMLD makes us a party that must know where the money comes from — just as with a classical wire transfer."
How on-chain forensics supports banks
Traditional KYC logic is not suited for source-of-funds checks on crypto transactions — customers cannot produce a "pay slip" for received BTC. Instead, on-chain evidence is required: where does the address come from, what is its transaction history, are there links to mixers, sanctions lists, or suspicious clusters?
Exactly this is what Coinator delivers. A typical workflow in a bank compliance team:
- Customer transfers coins to the bank's custody address.
- System automatically checks the address history in Coinator.
- Flag raised on suspicion (mixer contact, OFAC proximity, unusual fan-in patterns).
- Manual review by compliance team with detailed report.
Our take
6AMLD marks the end of the grey zone in which some banks have held back on crypto topics. Those who do not actively review carry the risk — and "not reviewing" is no longer an option.
Banks and AML teams planning a structured build-up of on-chain capability can request consulting and training.