Will I still be able to hold privacy coins in my wallet?

The AMLR prohibits providers from keeping accounts that allow anonymity, including through anonymity-enhancing coins. It contains no rule banning you from holding them in a self-hosted wallet; what may change is that your exchange stops offering them.

When does the AMLR apply?

From July 10, 2027, directly in every Member State, under Article 90. Some AMLA technical standards and guidelines are still awaiting adoption.

Will my exchange ask me to prove a wallet is mine?

It may. Since December 30, 2024, for transfers of more than EUR 1,000 involving a self-hosted address, the provider must assess whether that address is yours. AMLA will issue guidelines on how to verify this.

Does the cash payment limit change in Spain?

Not in substance. The AMLR sets an EU limit of EUR 10,000 but lets lower national limits stay, and Spain already applies EUR 1,000 where a business or professional is involved.

AMLR and Crypto: What Changes in July 2027

Last reviewed: October 22, 2026.

On July 10, 2027, Regulation (EU) 2024/1624, known as the AMLR, starts to apply. It is the EU's new anti-money laundering regulation, and because it is a regulation rather than a directive, it will apply directly in every Member State. If you buy, sell or hold crypto on an exchange, the AMLR sets out what your provider may offer you, what information it will ask for and when it will ask where your funds come from.

What Is the AMLR and When Does It Apply?

The AMLR was adopted on May 31, 2024 and published in the Official Journal of the EU on June 19, 2024. Under Article 90, it applies from July 10, 2027 (with a later date, July 10, 2029, only for certain professional football entities). It is part of the EU anti-money laundering package that also created the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), based in Frankfurt.

For crypto users, the starting point is that crypto-asset service providers (CASPs authorized under MiCA) are "financial institutions" for AMLR purposes (Article 2(1), point 6(i)) and therefore obliged entities (Article 3). They have the same core duties as a bank: identify the customer, understand the purpose of the relationship and monitor transactions.

Does the AMLR Ban Privacy Coins?

Not exactly. Article 79(1) prohibits credit institutions, financial institutions and crypto-asset service providers from keeping anonymous crypto-asset accounts "as well as any account otherwise allowing for the anonymisation of the customer account holder or the anonymisation or increased obfuscation of transactions, including through anonymity-enhancing coins."

The regulation defines those coins as "crypto-assets that have built-in features designed to make crypto-asset transfer information anonymous, either systematically or optionally" (Article 2(1), point 25). It contains no list of tokens: which assets fall within the rule will depend on how supervisors and providers interpret it.

Three important nuances:

The ban applies to the provider, not to the individual. The AMLR contains no rule prohibiting you from holding such coins in your own wallet.
Self-hosted wallets are outside its scope. Recital 160 states that the prohibition does not apply to providers of hardware, software or self-hosted wallets insofar as they do not have access to those wallets.
Existing anonymous accounts cannot be used in any way until the holder goes through customer due diligence, that is, until they are identified.

In practice, exchanges operating in the EU are likely to review which assets they offer before July 2027. If you hold a token with anonymity features, keep an eye on your provider's notices.

What About Transfers to Your Own Wallet?

This part does not start in 2027. Regulation (EU) 2023/1113, the so-called travel rule, has applied since December 30, 2024. Articles 14(5) and 16(2) require the exchange to obtain and keep originator and beneficiary information when you send crypto to, or receive it from, a self-hosted address. Where the transfer exceeds EUR 1,000, the provider must also take adequate measures to assess whether that address is owned or controlled by you.

Article 40 of the AMLR adds that providers must assess the risk of transfers involving self-hosted addresses and apply at least one proportionate mitigating measure. These include identifying the originator or beneficiary, requiring additional information on the origin and destination of the crypto-assets and enhanced ongoing monitoring. By July 10, 2027, AMLA must issue guidelines on these measures and on how to verify that a self-hosted address belongs to the customer.

When Will Your Exchange Ask for More Information?

The AMLR sets specific thresholds for crypto providers. Under Article 19(3), they must apply full customer due diligence to occasional transactions of EUR 1,000 or more, and at least identify the customer below that amount. In a business relationship, such as an exchange account, due diligence always applies.

Due diligence includes understanding the purpose of the relationship and, as appropriate, the origin and destination of funds (Article 25), as well as ongoing monitoring of transactions, including the source of funds where necessary (Article 20). In higher-risk situations, the provider may ask for additional information on the source of funds and source of wealth (Article 34).

The details will be set out in technical standards. On October 1, 2026, AMLA announced that it had finalized and submitted to the European Commission three sets of draft regulatory technical standards, including those on customer due diligence and on distinguishing occasional transactions from business relationships. According to AMLA, they are proposed to apply six months after entry into force, once adopted and published in the Official Journal.

The EUR 10,000 Cash Limit and the Situation in Spain

Article 80 of the AMLR sets an EU-wide limit of EUR 10,000 on cash payments accepted or made by persons trading in goods or providing services. It does not apply to payments between individuals who are not acting in a professional capacity, and Member States may keep or adopt lower limits.

Spain already has a stricter one: Article 7 of Law 7/2012 bans cash payments of EUR 1,000 or more where one of the parties acts as a business or professional (EUR 10,000 if the payer is an individual without tax residence in Spain who is not acting in a business or professional capacity). Because the AMLR lets national limits that are lower stay in place, little changes there. It is still worth remembering if you plan to sell crypto for cash to a business or an exchange desk.

What You Can Do Now

Organize your history: statements from each exchange, transaction IDs (TxIDs) and your wallet addresses. They are the basis for explaining where each amount comes from.
Identify your self-hosted addresses. Your provider may ask you to prove that you control an address; the specific methods will be set by AMLA's guidelines and by your exchange.
Check whether you hold assets with anonymity features with an EU provider and read any notice about service changes carefully.
Prepare the answer before you are asked. If you plan to move a significant amount to your bank or an exchange, having your documents ready avoids delays and blocks.

Need to prove the source of your funds? FundsOrigin analyzes your wallet's public address and produces a PDF report you can attach to your documentation; whether to accept it is always up to the institution. Analyze your wallet and see the available options →

Sources

This content is for information only and does not constitute legal, tax or investment advice. How the rules apply in practice will depend on pending technical standards and guidelines and on each provider. Check your situation with a professional.

AMLR and Crypto: What Changes in July 2027 for Exchange Users