Today, the Swedish AML Act (lag (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism) has no general limit on cash payments. From 10 July 2027, the EU Anti-Money Laundering Regulation (AMLR), Regulation (EU) 2024/1624, applies directly in every Member State. Article 80 then introduces an EU-wide limit on large cash payments. The Swedish government memorandum Fi2026/01654 sets out how Sweden proposes to apply it. There is no bill yet.
What does Article 80 AMLR say?
Article 80(1) reads: "Persons trading in goods or providing services may accept or make a payment in cash only up to an amount of EUR 10 000 or the equivalent in national or foreign currency, whether the transaction is carried out in a single operation or in several operations which appear to be linked."
Three points matter:
- Receiving and paying. The limit applies both when you accept cash and when you pay it out.
- Split payments count together. Several operations that appear to be linked count as one transaction.
- Currency makes no difference. The limit applies to the equivalent in any national or foreign currency.
"Cash" means cash as defined in Regulation (EU) 2018/1672 (Article 2(1)(43) AMLR).
Who does the cash limit apply to?
The limit applies to "persons trading in goods or providing services". It is not limited to obliged entities under Article 3. The Swedish memorandum notes that the cash limit also applies to businesses other than cash traders (section 13.2, p. 521). It describes those covered as businesses that trade in goods or provide services (section 13.2.1, p. 523).
So an accounting firm, a law firm or a real estate agent that charges for its services is covered in the same way as a shop.
What are the exceptions?
Under Article 80(4), the limit does not apply to:
- payments between natural persons who are not acting in a professional capacity
- payments or deposits made at the premises of credit institutions, electronic money issuers and payment service providers
Payments or deposits at those premises above the limit must be reported to the FIU, within the deadlines the FIU sets (Article 80(4), second subparagraph).
If means of payment other than banknotes and coins become unavailable nationally because of force majeure, a Member State may temporarily suspend the limit and must inform the Commission (Article 80(7)). The Swedish memorandum proposes that the government should be able to decide this (section 13.3, p. 531).
Can a Member State set a lower limit?
Yes. Member States may adopt lower limits after consulting the European Central Bank (Article 80(2)). National limits already below EUR 10,000 continue to apply, and were to be notified to the Commission by 10 October 2024 (Article 80(3)).
The Swedish memorandum notes that Sweden has no existing cash limit (section 13.1, p. 517). It sets out arguments for a lower limit. According to the memorandum, the Riksbank, Sweden's central bank, recommends in its 2026 payments report a maximum of SEK 10,000 for cash purchases in retail. The memorandum also mentions lower limits in Denmark, Greece, Spain, Italy and Slovenia, among others (p. 518).
Its conclusion is still that Sweden should not use the option to lower the limit, so the limit would be EUR 10,000 (p. 518). One reason given is that cash traders are proposed to stay in scope as obliged entities, and the two thresholds need to fit together.
By 10 July 2030, the Commission must report on whether the limit should be adjusted (Article 88(d)).
What happens if the limit is breached?
AMLR requires Member States to take appropriate measures, including penalties, against persons acting in a professional capacity who are suspected of breaching the limit (Article 80(5)). Penalties must be proportionate to the seriousness of the breach (Article 80(6)).
The Swedish memorandum proposes the following:
| Question | Proposal or assessment in the memorandum |
|---|---|
| Criminal offence? | No. Breaches should not be a crime (section 13.1, pp. 517 and 519 to 520) |
| Penalty | An administrative fine decided by the supervisor (section 13.2.2, p. 526) |
| Natural person | SEK 10,000 to SEK 30,000 |
| Legal person | From SEK 20,000 up to SEK 240,000, in four bands based on turnover |
| Several breaches | One joint fine, at most twice the maximum amount |
| Supervisor | The government decides. The memorandum's view is that the County Administrative Boards of Skåne, Stockholm and Västra Götaland should do it (section 13.2, p. 520) |
| Powers | Orders that can carry a conditional fine, and on-site inspections (section 13.2.1, p. 522) |
The amounts are in the draft new Swedish AML Act, Chapter 10, Sections 9 to 11 (pp. 40 to 41).
Which threshold applies to customer due diligence for traders in goods?
The cash limit is not the same as the threshold for customer due diligence. These are the differences.
Today under the Swedish AML Act
A professional trader in goods is an obliged entity if cash payments can be expected to reach EUR 5,000 or more (Chapter 1, Section 2, point 16). CDD is then required for cash amounts of EUR 5,000 or more, including linked transactions (Chapter 3, Section 6).
From 2027 under AMLR
AMLR removes traders in goods who handle large cash amounts as a separate category. Recital 18 explains that traders in goods no longer need to be covered, with the exception of traders in precious metals, precious stones, other high-value goods and cultural goods. For the obliged entities that remain:
- an occasional transaction of at least EUR 10,000 requires CDD (Article 19(1)(b))
- an occasional transaction in cash of at least EUR 3,000 requires at least identification of the customer and verification of identity (Articles 19(4) and 20(1)(a))
- traders in precious metals, precious stones, high-value goods and cultural goods must treat the supplier of goods as a customer too (Article 19(6)(a))
The EUR 3,000 rule does not apply in Member States with a cash payment limit of EUR 3,000 or less (Article 19(4), second subparagraph). The Swedish memorandum proposes EUR 10,000.
Under the Swedish proposal
The memorandum proposes keeping cash traders in scope as a national choice. The threshold would be in Swedish kronor: a trader in goods is covered if cash payments can be expected to reach SEK 55,000 or more (section 5.3.3, pp. 226 to 227). The memorandum does not discuss the EUR 3,000 rule in Article 19(4).
| Swedish AML Act today | AMLR from 10 July 2027 | Swedish memorandum (proposal) | |
|---|---|---|---|
| General cash limit | None | EUR 10,000 (Art. 80(1)) | No lower limit |
| Traders in goods receiving cash | In scope from EUR 5,000 (Ch. 1, s. 2, point 16) | Not a separate category (recital 18) | In scope from SEK 55,000 |
| CDD for occasional cash transactions | EUR 5,000 for cash traders (Ch. 3, s. 6) | At least identification from EUR 3,000 (Art. 19(4)) | Not discussed |
What should you do now?
These are practical suggestions, not legal advice:
- Map your cash flows. Are there payments, or series of payments, that could approach EUR 10,000?
- Add a stop in your till and invoicing. Your procedure must catch split payments that appear to be linked.
- Check whether you are an obliged entity. Traders in precious metals, precious stones and high-value goods come into scope in 2027. See new obliged entities under AMLR.
- Update your CDD procedure. Obliged entities need a procedure for cash transactions from EUR 3,000. See our KYC guide.
- Follow the Swedish consultation. The SEK 55,000 threshold and the fines are proposals.
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