Home » What will be the actual impact of the European AMLR anti-money laundering framework?

What will be the actual impact of the European AMLR anti-money laundering framework?

by Tim

The implementation of regulatory frameworks can sometimes blur the lines between investor protection and broad-based surveillance. This situation applies more specifically to the AMLR (Anti-Money Laundering Regulation), which will take effect in the European Union starting in July 2027. It is an ambitious framework that requires some clarification in order to assess its actual scope without falling into alarmist paranoia.

AMLR: A Problematic Regulatory Framework?

Some still wonder what cryptocurrencies are good for. Perhaps to maintain a degree of independence from the surveillance applied to financial flows, at a time when cash is gradually disappearing, although it seems important to note that Sweden—a pioneer in the field for years—has ultimately backtracked on the issue.

This situation is further exacerbated by the introduction of central bank digital currencies (CBDCs) and the associated risk of potential control. This is an ongoing development within the European Union, with deployment expected in 2029, alongside a joint commitment to strict oversight of stablecoins.

In this context, independent researcher Shanaka Anslem Perera has just sounded the alarm over a bill that “treats every citizen like a criminal.” At issue are transactions such as buying a car with cash or sending more than 1,000 euros in Bitcoin, which could soon be viewed with suspicion.

This is an opportunity for Shanaka Anslem Perera to point out that the legitimate fight against money laundering—estimated at $500 billion annually—carries an unintended consequence in the form of potential mass surveillance of the European Union’s population.

Cash payments: no change for the French

In practice, this regulation involves a highly controversial measure aimed at limiting cash payments to a maximum of 10,000 euros.

This situation does not really affect France, since restrictions already exist in this area between individuals and businesses, with a maximum amount set at 1,000 euros. As for cash payments made directly between individuals, this limit rises to 15,000 euros.

The goal of the AMLR is therefore to harmonize practices among European Union member states, as cash remains highly popular in countries like Germany and Austria, which are directly impacted by this new limit.

Cryptocurrencies: More Targeted Than Generalized Surveillance?

Regarding cryptocurrency transfers, the objective of this text—which builds on the Transfer of Funds Regulation (TFR)—does not imply generalized surveillance of on-chain transactions, as was suggested on social media.

In fact, the announced tracking will apply “only” to transactions exceeding 1,000 euros originating from a self-custody wallet and involving interaction with a regulated service provider (PSAN), such as cryptocurrency exchange platforms like Binance, Kraken, or Coinbase.

In the case of a transfer between individuals (directly from wallet to wallet), this monitoring does not apply.

However, it is important to note that any transaction carried out through a regulated service requires the identification of both parties and the recording of transaction information.

Collateral risks of crypto data leaks

At the same time, another development is emerging as a potential risk: the implementation of the European DAC8 directive, which expands the scope of tax obligations to include cryptocurrencies in order to enhance the fight against tax fraud and evasion.

This drive for transparency exposes the information collected on taxpayers’ digital assets to major risks due to its centralized nature. Indeed, this could enable cybercriminals or organized networks to identify prime targets.

One need only look at how a tax official has recently been suspected of passing confidential tax data to criminal groups to understand the potential scale of this security breach, particularly in the context of kidnappings and the holding of crypto figures hostage to demand ransoms.

Tax official suspected of leaking information to organized crime

Tax official suspected of leaking information to organized crime

In an ecosystem where the principle of self-custody is based on individual responsibility, the protection of personal data is now just as crucial as that of private keys.

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