The 6th Anti-Money Laundering Directive: What US Businesses with EU Exposure Need to Know

If your business pays EU-based vendors, partners, or counterparties, the 6th Anti-Money Laundering Directive (AMLD6) raises the compliance bar — even for US companies. Broader criminal liability, expanded predicate offenses, and tighter screening obligations mean that what was acceptable due diligence under AMLD5 may no longer be enough.

What Is AMLD6?

The 6th Anti-Money Laundering Directive is the EU's framework for combating money laundering and terrorist financing. It builds on AMLD5 with three significant changes that matter for US companies doing business with EU entities:

1. Expanded predicate offenses AMLD6 broadens the list of criminal activities that can trigger money laundering charges — adding cybercrime, environmental crime, and tax offenses. This matters because it widens the pool of counterparties that could be implicated in laundering activity.

2. Extended criminal liability Senior executives and directors can now be held personally liable for AML failures — not just the organization. This includes non-EU companies if the laundering activity involves EU transactions.

3. Aiding and abetting AMLD6 introduced the concept of indirect involvement — meaning a US business that processes payments through a sanctioned or high-risk EU entity without adequate screening could face liability, even without direct knowledge of wrongdoing.

Why This Affects US Companies

AMLD6 is an EU directive, but its reach extends beyond EU borders in a few important ways:

  • You pay EU vendors or contractors — any payment flowing into the EU creates exposure if the recipient is on a sanctions list or implicated in money laundering
  • You have EU customers or partners — onboarding EU counterparties without screening them against relevant EU watchlists creates risk
  • You process payments through EU financial institutions — EU banks operating under AMLD6 will apply their own due diligence to your transactions, and failures on your end can create friction or blocked payments
  • Your EU subsidiaries or affiliates — if you have any EU presence, AMLD6 compliance is mandatory for that entity, and gaps flow upstream

The practical question for most US AP teams and compliance officers isn't whether AMLD6 applies to them directly — it's whether their screening program is broad enough to catch the EU counterparties that now carry elevated risk.

What Adequate EU Screening Looks Like

AMLD6 doesn't prescribe a specific list of databases to check. What it requires is a risk-based approach — meaning your screening program should be proportionate to your EU exposure. At minimum, for any EU vendor, counterparty, or partner, that means checking against:

  • EU Financial Sanctions Files (FSF) — the core EU sanctions list
  • EU Council Official Journal Sanctioned Entities
  • EU Consolidated Travel Bans
  • Country-level lists for the specific member states you operate in — France, Germany, Netherlands, UK, and others each maintain their own sanctions and PEP lists
  • Politically exposed persons (PEP) lists for relevant jurisdictions

Checking OFAC alone is not sufficient for EU counterparties. OFAC covers US sanctions — EU sanctions lists are maintained separately and the overlap is incomplete.

How TIN Comply Covers EU Screening

TIN Comply screens against 250+ global sanctions and watchlists, including comprehensive EU coverage:

  • EU Financial Sanctions Files
  • EU Council Official Journal Sanctioned Entities
  • EU Consolidated Travel Bans
  • EU Early Detection and Exclusion System (EDES)
  • EU ESMA Sanctions and Suspensions
  • EU Prominent Public Functions and PEP lists
  • Country-level lists covering UK, France, Germany, Netherlands, Russia, Belgium, Poland, Switzerland, Ukraine, and more

Every screening is logged with a timestamp and full audit trail — so if a transaction is ever questioned, you have documented evidence of the check.

Start a free trial and run your EU vendor list against our full sanctions database.

Bottom Line

AMLD6 is not a future compliance problem for US businesses — it's a current one. If you pay EU vendors, onboard EU partners, or process transactions through EU financial institutions, your screening program needs to cover EU-specific watchlists, not just OFAC. The businesses most at risk are those still running US-only screening against a counterparty base that has grown internationally.

This article is for informational purposes only and does not constitute legal or compliance advice. Consult a qualified AML or legal professional for guidance specific to your organization.