Key Moments:
- Regulation (EU) 2024/1624, approved in 2024, sets a €10,000 cash payment limit effective July 2027
- From 2026, casinos and operators are obligated to upgrade internal controls and due diligence procedures
- Non-compliance can lead to significant fines, with AMLA overseeing enforcement and coordination
Background on Regulation (EU) 2024/1624
Regulation (EU) 2024/1624, commonly referred to as the AML Regulation, aims to combat money laundering and terrorist financing by capping cash payments within the European Economic Area. Approved in 2024 by the European Parliament and the Council, the regulation specifically targets sectors vulnerable to illicit capital flows, such as casinos.
The rule prohibits accepting or making cash payments of €10,000 or more in single or multiple related transactions, as specified in Article 80. From the €3,000 threshold, further controls must be implemented to improve fund traceability. The regulation is part of a wider AML/CFT framework that will be phased in from 2025 through 2027. Member States have the authority to set stricter limits based on internal risk assessments, thereby allowing tailored national adaptations to sector-specific risks and consumer behaviors.
Casino Sector Steps Up Preparation
Casinos and gambling operators are classified as “obliged entities” under the AMLR system. This designation requires implementation of enhanced identification checks, comprehensive compliance adaptations, and detailed documentation of funds originating from chip purchases, deposits, and substantial cash-outs by 2026.
The European Gaming and Betting Association (EGBA) highlighted the new regulatory landscape, stating: “the harmonisation of cash limits across the European Union eliminates regulatory gaps, promotes cleaner operations and obliges all operators to raise their risk prevention standards.”
Increased Oversight and Sanctions
The European Anti-Money Laundering Authority (AMLA) is tasked with directly issuing substantial fines and coordinating inspections among Member States in cases of regulatory breaches. Germany has already declared its intention to adopt the regulation’s payment and reporting requirements from early 2026, implementing digital records for any transaction surpassing €3,000.
Regulation (EU) 2024/1624 adds new layers of responsibility such as risk-based methodology development, periodic audits, and ongoing verifications for covered entities, as outlined in Articles 29 through 35. Proportional sanctions add further incentive for operators to maintain full compliance.
Sector-Wide Adoption and Cross-Border Consistency
According to EGBA, a review of corporate responsibility policies and internal codes of conduct will take place between 2025 and 2026, ensuring alignment with AMLR standards before the regulation’s full enforcement in 2027. This aims to establish consistency in cross-border operations and remove regulatory disparities that previously facilitated illicit activity.
The upcoming year is expected to be pivotal as national authorities and AMLA coordinate to enforce the updated regulations uniformly. Casinos that initiate these compliance measures promptly may reap lasting advantages in an environment with continually increasing regulatory expectations.
| Key Provision | Description | Implementation Timeline |
|---|---|---|
| €10,000 Cash Payment Cap | Ban on cash payments at or above €10,000 in single or linked transactions | Mandatory from July 2027 |
| Enhanced Controls From €3,000 | Internal controls required for transactions of €3,000 or more | Gradual rollout between 2025 – 2027 |
| National Adaptations Allowed | Member States may set lower cash limits based on internal risk | As per Member State discretion |
| AMLA Enforcement | Direct supervision and fine issuance for non-compliance | Ongoing from 2026 |
- Author
Daniel Williams
