The three numbers everybody cites wrongly
The cash limit, the beneficial ownership threshold and the application date, each stated the way the text actually states it rather than the way it is repeated.
The next lesson is part of the course
The 2027 AML package: a gap analysis for your entity · List price 149 euros · 12 months of access.
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Three figures from this package are quoted constantly, and all three are quoted wrongly. Getting them right is worth more than reading the whole regulation badly. The first is the cash limit. Ten thousand euros. What is almost always missed is that it is a ceiling, not a fixed rule. Member states may set a lower limit.
So the number that applies to you depends on where you operate, and an entity operating in several member states does not have one number, it has several. The second is the beneficial ownership threshold. Twenty five percent is retained, and people stop there. The regulation also gives the Commission power to lower it by delegated act, to fifteen percent, for categories of higher risk. So the correct statement is not, it stays at twenty five. It is, it stays at twenty five, and it is explicitly designed to move for some categories.
That has a system consequence worth acting on now. If your screening and onboarding tooling has twenty five percent written into it as a constant rather than as a parameter, you have a change request that has to be raised, scoped and scheduled before anybody knows what the new number is. That is a long lead item hiding behind a small one. The third is the date. The tenth of July 2027, with an exception: professional football clubs and football agents come in on the tenth of July 2029.
It is a small carve out and most of you will never touch it, but it is a useful test. Anybody who tells you the package applies on one single date has not read it. The habit underneath all three is the same. A number in this regulation is rarely just a number. It is a number plus who can change it, plus when it starts.
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All three figures are in Regulation (EU) 2024/1624 itself. Article 80 is the EUR 10 000 limit on large cash payments, expressed as a ceiling, with Member States able to set a lower one. Article 52(1) retains the 25 percent beneficial ownership threshold and article 52(2) gives the Commission the power to lower it by delegated act for categories of corporate entities exposed to higher risk. Article 90 carries the application date of 10 July 2027 and the later date of 10 July 2029 for professional football clubs and agents.
- Regulation (EU) 2024/1624, the three figures: articles 80, 52 and 90 EUR-Lex, official Journal. Article 80 is the EUR 10 000 limit on large cash payments and the power of Member States to set a lower one, article 52(1) is the 25 percent beneficial ownership threshold and article 52(2) the power of the Commission to lower it by delegated act for categories exposed to higher risk, and article 90 carries the application date of 10 July 2027 together with the later date of 10 July 2029 for professional football clubs and agents https://eur-lex.europa.eu/eli/reg/2024/1624/oj
Content written from the primary sources. Each instrument carries its own verification date in the source register. Content version: 25 September 2026
The whole module as one article
All three transcripts of Module 1 in order with the sources at the end, typeset for reading in one sitting and for printing.
Eight questions, pass mark 6
Six multiple choice and two scenarios on Module 1. Pass and you get a printable certificate carrying your name, the date and the module runtime.
The gap assessment
The worksheet this course is built around: current position, required position, owner and target date, saved against your organisation and exportable as CSV.
The source register
One table for all three published courses, held under the AML course: every instrument each course relies on, with its date, official reference, course and module. The rows of this course name it in the module column.