6th EU anti-money laundering directive (6AMLD): what changes concretely for Belgian regulated entities

6AMLD in brief

The 6th Anti-Money Laundering Directive (EU 2018/1673), transposed into Belgian law from 2020, marks a paradigm shift: it does not merely broaden the scope of money laundering, it harmonizes the predicate offenses and tightens criminal liability.

Unlike the 4th and 5th directives that mainly targeted preventive obligations of regulated entities (KYC, UBO, CTIF reports — see the Act of 18/09/2017), 6AMLD targets criminal law itself. But its indirect effects on regulated professions are massive.

The key concept: predicate offenses

Money laundering is a derivative offense: it presumes another crime generated the laundered funds. Before 6AMLD, Member States freely defined which offenses could underpin laundering. Now, 22 categories of predicate offenses are harmonized at European level.

The 22 harmonized predicate offenses

Participation in an organized criminal group

Terrorism (all forms)

Trafficking in human beings and migrant smuggling

Sexual exploitation, including of minors

Illicit trafficking in narcotic and psychotropic substances

Illicit arms trafficking

Illicit trafficking in stolen goods

Corruption

Fraud (all forms)

Counterfeiting of currency

Counterfeiting and piracy of products

Environmental crimes

Murder and grievous bodily harm

Kidnapping, illegal restraint, hostage-taking

Aggravated theft

Smuggling (including excise products)

Tax crimes (including aggravated tax evasion)

Extortion

Forgery

Piracy

Insider dealing and market manipulation

Cybercrime

Offenses 17 (tax) and 22 (cyber) are notable additions compared to the prior framework.

What changes concretely in KYC

For a Belgian regulated entity (law firm, accountant, company service provider), 6AMLD requires revising the risk assessment to explicitly include:

Reinforced tax risk

• Aggravated tax evasion becomes a predicate offense. In practice: if you know or suspect a client uses structures to evade tax above the criminal threshold, you are exposed.

• Practically: cross-check VAT returns, economic consistency and corporate purpose.

• See our risk assessment methodology.

Cyber risk

• Funds from ransomware, online fraud, carding are now clearly predicate.

• Sensitize teams to weak signals: crypto-assets received from unidentified wallets, transfers following CEO fraud, etc.

Self-laundering punished

6AMLD requires the criminalization of self-laundering: the person who committed the predicate offense is also punishable for laundering the funds. Previously, some states (including Belgium before 2017) did not prosecute it.

Impact for regulated entities: a client laundering their own money from tax fraud is now fully liable. No "not my problem, they already committed the main offense".

Legal-person liability

Legal persons (companies, non-profits) can be criminally convicted for laundering (not just administratively). Sanctions:

• Fines: up to 5 % of annual turnover

• Bans: business activity, access to public aids, public contracts

• Judicial liquidation in the most serious cases

Harmonized minimum sanctions

6AMLD imposes minimum sentences for laundering:

• Minimum 4 years' imprisonment for serious cases (gang leaders, large amounts)

• Ancillary sanctions: asset confiscation, professional ban

Impact on CTIF reporting

With 6AMLD, suspicions to report broaden:

• Suspicion of aggravated tax fraud: report possible if the criminal threshold is crossed (in Belgium, indicative threshold: evaded taxes ≥ €50,000)

• Suspicion of cyberfraud: ransomware received from client, funds transiting via crypto mixers

• Suspicion of self-laundering: a client poorly justifying the origin of their own funds

See our CTIF guide.

2024 update of 6AMLD

In 2024, the EU adopted an update of 6AMLD (Directive (EU) 2024/1654) that:

• Adds organ trafficking and certain environmental crimes

• Reinforces cross-border sanctions

• Aligns with the single AML regulation 2024/1624 (see our AML evolution 2026-2030 article)

This update is applicable in Belgium since the late-2025 transposition.

Checklist for 6AMLD adaptation

For a regulated entity that has not yet updated its framework:

Revise the risk assessment to include offenses 17 and 22 (tax and cyber)

Update the AML policy with explicit mention of new offenses

Train teams on new red flags (tax and cyber)

Calibrate monitoring to detect crypto flows and tax anomalies

Document reasoned non-reports on these new types

Adapt client contracts to clarify transparency obligations on source of funds

See also the 2026 checklist.

How Company Belgium integrates 6AMLD

Company Belgium's regulatory base includes up-to-date 6AMLD:

• Risk assessment integrating the 22 predicate offenses

• KYC templates with specific tax and cyber clauses

• Monitoring with crypto and tax scenarios

• Direct linkage to harmonized EU sanctions lists

• Quarterly watch on 6AMLD evolutions

• Ongoing AMLCO training on new typologies

See also the 2026 RegTech landscape.

Bottom line

6AMLD does not change the KYC mechanism, but considerably broadens the field of suspicions you must detect. Aggravated tax, cybercrime, self-laundering are now fully integrated predicate offenses.

For a Belgian regulated entity, the right reflex in 2026: add these dimensions to your risk matrix, train teams on new red flags, and configure your RegTech tool to produce targeted alerts.