Today, Swedish businesses apply the Swedish AML Act (2017:630). From 10 July 2027, the EU Anti-Money Laundering Regulation (AMLR), Regulation (EU) 2024/1624, applies directly in every Member State. The Swedish government memorandum Fi2026/01654 proposes supplementary Swedish rules from the same date. There is no bill yet, so everything said about the memorandum below is a proposal.
Who is covered today, and who from 2027?
In Sweden today, Chapter 1, Section 2 of the Swedish AML Act lists 24 types of activity. Anyone carrying out one of them is an obliged entity under the Act.
From 2027, AMLR sets the list. Under Article 3, credit institutions and financial institutions are obliged entities. So are the natural and legal persons listed in Article 3(3)(a) to (o), "acting in the exercise of their professional activities".
The Swedish memorandum stresses that the activity decides, not the name of the business (section 5.1, p. 208).
Which businesses are new under AMLR?
The table shows the Article 3(3) categories with no own category in the Swedish AML Act today.
| Business | AMLR | Swedish AML Act today |
|---|---|---|
| Trading in precious metals and stones as a regular or principal professional activity | Art. 3(3)(e) | No own category. Covered only as a cash trader (Ch. 1, s. 2, point 16) |
| Trading in high-value goods as a regular or principal professional activity | Art. 3(3)(f) | No own category. Covered only as a cash trader (Ch. 1, s. 2, point 16) |
| Crowdfunding intermediaries | Art. 3(3)(h) | No. Only crowdfunding service providers (point 12) |
| Credit intermediaries for mortgage and consumer credits that are not credit or financial institutions | Art. 3(3)(k) | No own category |
| Investment migration operators | Art. 3(3)(l) | No |
| Non-financial mixed activity holding companies | Art. 3(3)(m) | No |
| Football agents | Art. 3(3)(n) | No |
| Professional football clubs, for certain transactions | Art. 3(3)(o) | No |
Precious metals, precious stones and high-value goods
Annex V lists the precious metals and stones, including gold, silver, platinum, diamonds, rubies, sapphires and emeralds. Annex IV lists the high-value goods:
- jewellery, gold- or silversmith articles of a value exceeding EUR 10,000
- clocks and watches of a value exceeding EUR 10,000
- motor vehicles of a price exceeding EUR 250,000
- aircraft and watercraft of a price exceeding EUR 7,500,000
In Sweden today, these traders are covered only if they can be expected to pay or receive cash of EUR 5,000 or more (Ch. 1, s. 2, point 16). From 2027, they are covered regardless of how the customer pays, if the trade is regular or principal.
The memorandum labels them lyxvaruhandlare, luxury goods dealers (section 5.1.7, p. 217). It takes the view that the County Administrative Boards of Skåne, Stockholm and Västra Götaland should supervise them (section 8.2, p. 272).
Crowdfunding intermediaries
A crowdfunding intermediary runs an internet-based platform that matches project owners and funders, without being a provider under Regulation (EU) 2020/1503 (Article 2(1)(16)). The memorandum notes that these businesses are not regulated in Swedish law today (section 5.1.9, p. 219). It suggests Finansinspektionen, the Swedish financial supervisory authority, as supervisor (section 8.2, p. 272).
Credit intermediaries, investment migration and holding companies
- Credit intermediaries (Article 3(3)(k)). Intermediaries acting under the responsibility of a creditor or another credit intermediary are excluded. According to the memorandum, the point could cover the larger credit intermediaries that need a licence in Sweden from 20 November 2026 (section 5.1.12, p. 221).
- Investment migration (Article 3(3)(l)). Swedish law grants no residence permits in exchange for investment. The memorandum concludes that no such operators should exist in Sweden (section 5.1.13, p. 222).
- Non-financial mixed activity holding companies (Article 3(3)(m)). This is a parent undertaking, not itself a subsidiary, with at least one subsidiary that is an obliged entity under Article 3(3) (Article 2(1)(13)). The memorandum notes there is no equivalent in the Swedish AML Act (section 5.1.14, p. 222).
Certain financial holding companies also become obliged entities, as financial institutions (Article 2(1)(6)(a)). The memorandum covers this in section 5.1.1 (p. 210).
Football agents and professional football clubs
For football agents and professional football clubs, AMLR applies from 10 July 2029 (Article 90). Clubs are covered only for transactions with an investor, a sponsor, football agents or other intermediaries, and for player transfers (Article 3(3)(o)).
Member States may exempt clubs in the top national division with a total annual turnover below EUR 5,000,000 in each of the previous two calendar years, on the basis of proven low risk (Article 5(1)). The Swedish memorandum does not discuss football in detail and leaves the exemption question aside (section 5.1, p. 208, and 5.2, p. 222).
Which existing categories are widened?
- Cultural goods (Article 3(3)(i) and (j)). The Swedish AML Act refers to works of art (Ch. 1, s. 2, point 24). AMLR refers to cultural goods as listed in Annex I to Regulation (EC) No 116/2009. The memorandum notes that NFTs and other modern art then fall outside. It proposes covering trade in other works of art in the same way, at EUR 10,000 or more (section 5.1.10, p. 220). Point (j) covers free zones and customs warehouses, but the memorandum notes there are currently no free zones in Sweden (section 5.1.11, p. 221).
- Real estate (Article 3(3)(d)). AMLR also covers other real estate professionals acting as intermediaries. In the memorandum's view, in Sweden these are in practice only real estate agents and agencies (section 5.1.5, pp. 216 to 217).
Who is already covered in Sweden?
Two groups sometimes described as new are already covered by the Swedish AML Act:
- Crypto-asset service providers. They are covered by Ch. 1, s. 2, point 13, since 30 December 2024 according to the memorandum (section 5.1.1, p. 212). Under AMLR they fall within the definition of financial institution (Article 2(1)(6)(i)).
- Crowdfunding service providers. They are covered by Ch. 1, s. 2, point 12, if the business is a legal person established in Sweden. The memorandum describes this as a Swedish choice that now becomes EU-wide (section 5.3.1, p. 224).
Who drops out at EU level?
AMLR removes traders in goods who handle large cash amounts as a separate category. It replaces that rule with a limit on cash payments (recital 18). See the cash payment limit in AMLR. The memorandum proposes keeping these cash traders in scope in Sweden as a national choice, with a threshold of SEK 55,000 (section 5.3.3, pp. 226 to 227).
The memorandum also proposes keeping pawnbrokers in scope (section 5.3.2, p. 225). Businesses that only provide account information services will be excluded again, because AMLR leaves that payment service out of the definition of financial institution (section 5.1.1, p. 210).
What does Sweden propose to add?
The memorandum proposes two new Swedish categories (section 5.3.4, pp. 227 to 228):
- professional trade in goods where payments in crypto-assets can be expected to reach SEK 55,000 or more
- issuing electronic money usable only in a limited network, such as gift cards, where payments in crypto-assets can be expected to reach SEK 5,000 or more
Selling newly formed limited companies and brokering legal persons will continue to count as trust or company services (section 5.1.4, p. 214). This matches Ch. 1, s. 4, second paragraph, point 1 of the Swedish AML Act today.
What must a new obliged entity do?
An obliged entity must apply AMLR in full. That includes a business-wide risk assessment (Article 10), customer due diligence under Articles 19 and 20, and records of what you did.
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)). Traders in high-value goods must also report certain sales to the FIU when the goods are acquired for non-commercial purposes: motor vehicles from EUR 250,000, and watercraft and aircraft from EUR 7,500,000 (Article 74(1)).
Under the Swedish proposal, obliged entities without a licence or similar approval must register with Bolagsverket, the Swedish Companies Registration Office. This also applies to new obliged entities (section 6.1.1, p. 237).
These are practical suggestions, not legal advice:
- Decide whether you are in scope. Check Article 3(3) and Annexes IV and V against what you sell or broker.
- Carry out a business-wide risk assessment before you set your customer measures.
- Set up customer due diligence. Start from Article 20 and our KYC guide.
- Plan ongoing monitoring. Work out review dates with the review interval tool.
- Follow the Swedish consultation. The proposal can change before a bill.
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