The Sixth Anti-Money Laundering Directive (AMLD6) is set to take effect on July 10, 2027, introducing stricter Know Your Customer (KYC) and Ultimate Beneficial Owner (UBO) requirements, enhanced Politically Exposed Person (PEP) Monitoring and new Public Register restrictions. 

What does this mean for businesses in Denmark?

While some details are still being finalized, Danish companies must start preparing for the most comprehensive Anti-Money Laundering (AML) framework the EU has introduced to date.

New KYC Requirements: More Data, Stricter Oversight

AMLD6 expands KYC obligations significantly. Businesses will need to collect and verify more personal information, including:

• Place of Birth (mandatory for private individuals)
• Nationality/Citizenship (newly required for private individuals)
• Refugee Status (to be recorded where applicable)
• Residential Address (must be provided and verified)

These data requirements will also extend to UBOs, meaning businesses must collect the same level of detail as they do for customers. The threshold for UBO identification is also shifting from "more than 25%" ownership to "minimum 25%", broadening the scope of who qualifies.

Furthermore, a group of people - such as a family - can now collectively be recognized as UBOs, requiring businesses to track ownership in more complex structures.

Ongoing Due Diligence (ODD) Standardization

For the first time, the EU is introducing uniform ODD update cycles:

• High-risk counterparties must be reviewed every year.
• Lower-risk counterparties will follow a five-year review cycle.

This replaces varying common business practices and standards that were previously self-determined (for example, the 1-, 2-, and 3-year cycles found with companies in Luxembourg) and will impact how organizations manage KYC updates.

Increased PEP Monitoring and New Compliance Policies

AMLD6 introduces stricter monitoring of politically exposed persons (PEPs), requiring businesses to continuously assess Risk Levels. Additionally, new policy and procedural requirements will apply to all regulated companies, including:

• Mandatory AML/Counter Terrorist Financing (CTF) policies and procedures
• Employee training on regulatory requirements
• Specific policies for handling Sanctions Compliance

Non-compliance with these new standards will result in increased regulatory scrutiny and enforcement actions, reinforcing the importance of robust AML governance.

What This Means for Businesses

AMLD6 will require businesses to collect more customer and UBO data, maintain stricter compliance frameworks, and adapt to new Due Diligence (DD) timelines. While this strengthens AML controls, it also increases operational burdens for compliance teams.

In my next article, I’ll explore how AMLD6’s restrictions on public registers could impact KYC collection - and why companies must prepare for a more challenging data access landscape.

‍

***************

WANT MORE? SOME RELATED KYC ARTICLES

AMLD6 UBO Register Restrictions: What Danish Companies Must Do to Maintain KYC Compliance

The EU and Denmark wants to know who really controls your company

Initial Thoughts on the June 2024 AML/CFT legislative package in its Official Journal