AML 2024/1624 Corrigendum: what changes for banks, notaries and crypto

Key data

If your company is among the entities subject to European anti-money laundering regulations, you have a concrete problem on your hands: the text of Regulation (EU) 2024/1624 that you apply may have changed. The corrigendum published on 31 March 2026 under reference CELEX:32024R1624R(02) introduces technical modifications that may directly affect how you identify customers, how you verify beneficial owners and when you must report suspicious transactions.

It is not a substantive policy change, but it may well be a change to a specific obligation. And in AML matters, the difference between the previous text and the corrected one may be the difference between compliance and non-compliance.

What does this regulation establish?

This document is a corrigendum (erratum) to Regulation (EU) 2024/1624 of the European Parliament and of the Council, on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.

Errata in European regulations are not minor matters: they correct the legally binding text. This means that the obligations you apply must be read against the corrected text, not the original. The areas that may be affected by the corrigendum are:

• Customer due diligence obligations
• Customer identification and identity verification
• Identification of beneficial owners (ultimate beneficial owners of legal structures)
• Reporting of suspicious transactions to competent authorities

Regulation (EU) 2024/1624 is the European reference standard on the prevention of money laundering and terrorist financing (AML/CFT) for the current regulatory cycle. This corrigendum updates its official text and is therefore the text that prevails for compliance purposes.

Economic and operational impact

The impact is not a direct cost from the corrigendum itself, but rather a risk of misalignment between the internal procedures you currently apply and the corrected text that is legally enforceable from its publication date.

The specific operational consequences are:

• Review of AML compliance manuals and internal procedures
• Update of customer and beneficial owner identification forms
• Possible revision of criteria for reporting suspicious transactions
• Training of the compliance team on the technical changes introduced
• Update of contracts or agreements with third parties performing delegated due diligence functions

The real economic risk lies in the sanctions regime: non-compliance with the obligations of Regulation (EU) 2024/1624 — already in its corrected version — may result in significant administrative sanctions. European AML legislation provides for substantial penalties for entities that do not correctly apply due diligence procedures or that fail to report suspicious transactions.

Who is affected?

The corrigendum affects all obliged entities under Regulation (EU) 2024/1624. These are:

• Financial institutions: banks, credit institutions and payment institutions
• Fund managers and investment entities
• Insurers with life or investment products
• Notaries
• Lawyers carrying out certain activities (real estate, corporate, tax transactions)
• Tax advisors
• Real estate agents
• Crypto-asset providers (exchanges, custodians, issuers)

If your professional or business activity falls into any of these categories, the corrected text is the one you must apply from its publication date.

Practical example

Imagine you are the compliance officer of a tax advisory firm with corporate clients. Your AML procedures manual sets out the beneficial owner identification process in accordance with the original text of Regulation (EU) 2024/1624.

With the publication of this corrigendum on 31 March 2026, the legally enforceable text has changed in the corrected points. If the erratum affects, for example, the threshold or the verification procedure for the beneficial owner, and your manual does not reflect the corrected text, you are applying a procedure that is no longer compliant with the current regulation.

In an inspection or in the event of an incident, the competent authority will assess your compliance against the corrected text, not the original. That is why the first step is to identify exactly which paragraphs or articles have been corrected and compare them with your current procedures.

The same applies to a crypto-asset provider with protocols for reporting suspicious transactions: if the corrigendum affects the criteria or reporting deadlines, it must update its systems and team training immediately.

What should companies do now?

1. Locate the corrected text: Access reference CELEX:32024R1624R(02) on EUR-Lex and download the official corrected version of Regulation (EU) 2024/1624.
2. Identify the amended articles: Compare the corrected text with the original to pinpoint exactly which provisions have changed regarding due diligence, customer identification, beneficial owners or reporting of suspicious transactions.
3. Review internal procedures: Compare the amended articles against your current AML manuals, policies and forms. Update everything that does not conform to the corrected text.
4. Update team training: Inform those responsible for compliance, customer onboarding and suspicious transaction reporting about the specific changes introduced by the corrigendum.
5. Document the review process: Keep a written record that you have reviewed the corrected text and of the updates made. This documentation is key in the event of an inspection.
6. Consult a specialist if in doubt: If the corrigendum affects obligations that are unclear to you, consult an AML compliance specialist before the regulation is enforced by supervisory authorities.

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:32024R1624R(02)