Corrigendum AML Directive 2024/1640: what changes for obliged entities

Key data

If your company or firm works with AML/CFT regulation, the reference text you must use has changed. The corrigendum published on 31 March 2026 under reference CELEX:32024L1640R(03) corrects material errors in Directive 2024/1640 of the European Parliament and of the Council, relating to the mechanisms that Member States must establish to prevent the use of the financial system for money laundering or terrorist financing.

The corrections do not introduce new obligations or modify the substantive content of the regulation. However, the definitive text — the legally valid one — is the one that includes these corrections. Working with the previous version may generate inconsistencies in compliance programmes and in national transposition processes.

What does this regulation establish?

This corrigendum corrects material errors of a technical-legal nature in Directive 2024/1640. This is not a substantive amendment: the obligations, deadlines and scope of the original directive remain unchanged.

The practical impact is clear: the corrected text becomes the only text with full legal validity. This directly affects two key processes:

• National transposition: Member States must transpose the corrected directive into their national legal systems. Transposition must be carried out on the basis of the definitive text, not the version containing errors.
• Internal regulatory compliance: Compliance officers and legal advisors working with AML/CFT regulation must update their references to work with the corrected definitive text.

Directive 2024/1640 regulates the mechanisms that Member States must establish to prevent the use of the financial system for money laundering (AML) and terrorist financing (CFT). This corrigendum ensures that the text serving as the basis for those mechanisms is legally precise.

Economic and operational impact

The corrections are technical in nature and do not generate new direct costs arising from additional obligations. However, they do have a real operational impact for compliance departments and legal advisors specialising in AML/CFT:

• Updating internal documentation: Compliance manuals, AML policies and internal procedures that cite or reproduce articles from Directive 2024/1640 must be reviewed to ensure they reflect the corrected text.
• Review of training materials: If training sessions have been delivered or materials prepared based on the original text containing errors, it may be necessary to update that content.
• Monitoring national transposition: Member States will transpose the corrected text. Companies must monitor how each national legislation incorporates the directive, as the national transposition rules will be those generating directly enforceable obligations.

The operational cost is low if the update process is managed in an orderly manner. The risk increases if the correction is ignored and outdated references are used in audits, inspections or sanctioning proceedings.

Who is affected?

The corrigendum affects all obliged entities in the AML/CFT sphere that must comply with Directive 2024/1640, as well as those involved in its transposition and application:

• Financial institutions (banks, credit institutions, investment firms)
• Notaries
• Lawyers
• Financial managers and advisors
• Real estate agencies and companies
• Casinos and gambling operators
• Other AML obliged entities under applicable regulation
• Compliance officers and regulatory compliance managers
• Legal advisors specialising in AML/CFT
• National authorities responsible for transposing the directive

Practical example

A law firm active in real estate transactions — an AML obliged entity — has implemented a compliance programme that includes direct references to articles of Directive 2024/1640. The compliance officer has based the due diligence procedures on the original text of the directive.

Following the publication of corrigendum CELEX:32024L1640R(03) on 31 March 2026, the legally valid text is the corrected one. If the firm is subject to an inspection or audit and its internal procedures cite articles containing material errors from the original text, it may face inconsistencies that make it difficult to demonstrate compliance.

The concrete action: the compliance officer must identify which articles have been corrected in the definitive text, compare them with the internal references in the compliance programme, and update the affected documentation before the next review or audit.

What should companies do now?

1. Update internal regulatory references: Replace any reference to Directive 2024/1640 with the corrected text published under reference CELEX:32024L1640R(03). The definitive text is the only legally valid one.
2. Review the AML/CFT compliance programme: Verify that internal procedures, due diligence policies and compliance manuals do not reproduce articles containing the corrected material errors.
3. Update training materials: If training sessions or internal guides have been prepared based on the original text, review and update the affected content.
4. Monitor the national transposition process: Track how each Member State transposes the corrected directive. The directly enforceable obligations for companies will derive from the national transposition legislation.
5. Document the update: Keep a written record that the compliance programme has been reviewed and updated in accordance with the corrected text. This documentation is relevant in the event of an inspection or audit.

Official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32024L1640R(03)