EU anti-money laundering rules from 10 July 2027: UBO, cash limits and your Dutch BV

What changes on 10 July 2027

Until now every EU country has applied its own anti-money laundering law; in the Netherlands that is the Wwft. The package of 2024 replaces that patchwork with three texts. Regulation (EU) 2024/1624 holds the rules for banks, notaries, accountants, trust offices, real estate agents and the other businesses that must check their clients, the obliged entities. It applies directly from 10 July 2027, with the same text in every country. Directive (EU) 2024/1640 covers what stays national: the UBO registers, the supervisors and the financial intelligence units. Member states must apply it by 10 July 2027 as well. The third text created AMLA, the EU authority in Frankfurt.

For your Dutch BV the practical result is one set of questions wherever you bank in the EU. The Wwft keeps the national parts, such as the register and the supervisors; the client checks themselves come from the regulation. Everything on this page was checked against the official sources on 20 October 2026.

AMLA, the Anti-Money Laundering Authority, has its seat in Frankfurt and started its work in mid-2025. It writes the technical rules that fill in the regulation, coordinates the national supervisors and the financial intelligence units, and from 2028 directly supervises a selection of financial institutions with a high risk. A trading or holding BV deals with its bank, its notary and its accountant; those parties apply the rules that AMLA sets, and the Dutch supervisors keep the day-to-day supervision.

The beneficial owner: 25%, and the parent company outside the EU

The regulation defines the ultimate beneficial owner (UBO) in the same way for all 27 countries: a natural person who owns or controls 25% or more of the shares or voting rights, directly or through other companies, or who controls the company in another way. The Commission may set a lower threshold, between 15% and 25%, for categories of companies with a higher risk of money laundering. The Dutch Wwft uses 25% today, so for most foreign founders the UBO in 2027 is the same person as now. What changes is the depth of the check: your bank and your notary document the whole chain between the BV and the natural person at the top, with proof for every layer. A chain through a holding in Dubai, a trust in Jersey and a foundation in Panama takes weeks longer than a chain with one parent company and two shareholders. See how a Dutch bank checks the UBO.

New in the regulation: a company incorporated outside the EU that enters into a business relationship with a bank, a notary or another obliged entity in the EU must first have its beneficial owners registered in the central register of that EU country, where the risk of the relationship is medium-high or high. The registration is a condition for the relationship. The recitals limit the duty to legal entities in higher-risk situations; the detail of that risk test follows in the implementation. For a Dutch BV with a parent company in the United States, Turkey, India or the Gulf, the question in 2027 is whether the parent itself must appear in a European register before the BV can open an account or sign a deed. Today the parent abroad is described in the notary file and the bank file with its own documents: an extract from its register, the shareholder register and the identity documents of its owners. Collect those now; an EU register will ask for the same.

Cash: a limit of €10,000, identification from €3,000

From 10 July 2027 a business may accept at most €10,000 in cash for one payment, in every EU country. A member state may keep or set a lower limit. A trader in goods that accepts cash between €3,000 and €10,000 identifies the customer and the beneficial owner. Traders in precious metals and stones, in luxury cars, boats and aircraft and in cultural goods become obliged entities themselves, with full client checks. Crypto-asset service providers and crowdfunding platforms are covered from the same date. Professional football clubs and agents follow on 10 July 2029.

The Netherlands today: a UBO register with limited access

The public lost access to the Dutch UBO register after a ruling of the Court of Justice of the EU. The Wijzigingswet beperking toegang UBO-registers, adopted by the Senate on 8 July 2025, limits access to four groups: competent authorities and the financial intelligence unit, obliged entities that check their clients, people and organisations with a legitimate interest, and the registered company for its own data. Since 1 April 2026, notaries, banks, trust offices, life insurers, investment firms, credit providers, payment institutions and exchange offices request a certified UBO extract through KVK, by API or on kvk.nl. KVK expects API-UBO 2.0, with data files instead of PDF extracts, in mid-2027. The decree that defines the legitimate interest went to parliament as a draft on 2 April 2026; its start date is still open.

Your duties as owner of a BV stay the same: every UBO is registered at incorporation and every change is reported. See updating the UBO register after a change and the UBO register in 2026.

What a bank, a notary and Holdwise ask, and what to prepare now

The regulation changes the law; the questions are the ones you get today. At incorporation the notary identifies every founder and every UBO, checks the parent company up the chain and asks for the source of the share capital. The bank repeats this and adds the business: what the BV sells, to whom, in which countries, the expected turnover and the expected payments in and out. Holdwise asks the same questions first, in the document check, so the notary and the bank receive a complete file in one go. In order:

1. Draw the chain. From your BV up to every natural person with 25% or more, or with control in another way. One page, with percentages and countries. Keep the structure as short as the business needs.
2. Collect the documents per layer. A certified passport copy and a proof of address of every founder, director and UBO; for each company in the chain a recent register extract and its shareholder register. Banks want recent documents, so collect them close to the incorporation date.
3. Document the money and the business. The source of the share capital and of the first working capital, with bank statements or contracts, and a description of products, customers, countries, suppliers and expected turnover. Owners in a country on the EU list of high-risk third countries bring extra documents, because the bank applies enhanced checks.
4. Check where the parent is incorporated. A parent outside the EU may need a UBO registration in an EU register from 10 July 2027 before a new relationship. Have its file ready in English.
5. Check your cash. A BV that takes cash from customers sets its limit at €10,000 per payment and identifies customers from €3,000 in cash. Lower national limits may apply in the country of sale.
6. Plan the bank account with the incorporation. The same file serves the notary and the bank; start the bank conversation in the week of the deed. How the incorporation itself works: company formation in the Netherlands and incorporating a Dutch BV.

Questions founders ask

Sources

• Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing: eur-lex.europa.eu; EUR-Lex summary, Preventing abuse of the financial system (from 2027): eur-lex.europa.eu
• Council of the EU, Anti-money laundering: Council adopts package of rules (30 May 2024): consilium.europa.eu; Council and Parliament strike deal on stricter rules (18 January 2024): consilium.europa.eu
• AMLA, About AMLA: amla.europa.eu
• Eerste Kamer, Wijzigingswet beperking toegang UBO-registers (36.584): eerstekamer.nl
• KVK, status of the extended access to the UBO register: kvk.nl
• Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft), the Dutch anti-money laundering act.