EU Regulation 2024/1624 sets €2,000 AML due-diligence trigger for gambling

Regulation (EU) 2024/1624, published in June 2024, imposes customer due diligence rules for gambling services when bets, the collection of winnings, or both reach €2,000 or more, whether in a single transaction or linked transactions. The regulation will generally apply from 10 July 2027, and operators across EU Member States must adapt their AML programmes, customer verification and transaction-monitoring systems ahead of that date.

What the regulation requires for gambling operators

The regulation establishes specific circumstances in which customer identification and verification measures are mandatory. The most immediate practical threshold for gambling firms is €2,000: customer due diligence conditions apply when bets, the collection of winnings, or both reach that amount, whether through a single transaction or linked transactions. Operators must determine when identification and verification measures are required and ensure their procedures comply with the applicable rules.

The text also frames risk-based controls: businesses must assess money laundering and terrorist financing risks and apply appropriate measures based on the risks identified. Member States may grant full or partial exemptions to certain gambling service providers where risks are demonstrably low and the conditions established by the regulation are met; those exemptions are not automatic and do not apply across the sector without meeting the regulation’s conditions.

The regulation clarifies that the €2,000 threshold should not be read as a universal requirement to verify every customer before their first bet. It sets out specific circumstances for applying due diligence and requires monitoring transactions and identifying linked activity.

Timetable and related EU workstreams

The regulation is directly applicable in EU Member States from 10 July 2027. Related provisions under Directive (EU) 2024/1640 follow a separate transposition process at national level and therefore have different implementation mechanics.

The European Union’s Anti‑Money Laundering Authority (AMLA) is supporting consistent application across the bloc. On 1 October 2026, AMLA announced it had finalised three sets of draft regulatory technical standards for the private sector addressing the identification of business relationships and linked transactions, customer due diligence, and group‑wide AML arrangements. AMLA submitted those draft standards to the European Commission; they will only become applicable after the Commission’s adoption and publication process described in AMLA’s announcement.

Operational implications and industry view

Operators must review AML programmes, customer due diligence procedures, transaction‑monitoring systems and risk assessments ahead of the July 2027 deadline. Deloitte’s analysis for the gambling industry highlights the challenge of meeting the new obligations while preserving user access. Dániel Bognár, Director at Deloitte Central Europe’s Gambling Centre of Excellence, said:

"The challenge is not simply meeting new AML requirements. It is doing so while preserving the customer experience."

Deloitte recommends improvements in customer identification, transaction monitoring, data integration and risk assessment as preparation steps.

Practical next steps for operators

Operators should document risk assessments, map where the €2,000 threshold is met in their product flows, and check whether any Member State exemptions apply to their activities. Reviewing group‑wide AML arrangements and the draft technical standards submitted to the European Commission will help firms align internal controls with the expected detail of forthcoming rules. Regulation and b2b teams should coordinate implementation planning across legal, compliance and product functions.