The EU Anti-Money-Laundering Package: What Changes for Bullion Clients in 2027

The European Union's anti-money-laundering package — a directly applicable Regulation, a new Directive and the creation of the Anti-Money Laundering Authority (AMLA) in Frankfurt — replaces the patchwork of national rules that has governed our sector for two decades. Most provisions apply from 10 July 2027. Because a Regulation does not need transposition, the rules will be identical in Poland, Germany, Switzerland's EU-facing counterparts, and every other member state on the same day.

For custodians and dealers in precious metals the headline change is that we are named explicitly as obliged entities, with harmonised customer due diligence rules. In practice Real Vault has operated to this standard since we opened: every client is identified and verified before an account is created, beneficial owners of corporate clients are identified, and we keep records for the statutory period. What changes is the level of detail the law now prescribes and the documentation regulators can expect to see.

The most concrete new rule is an EU-wide cap on cash payments of €10,000. Real Vault does not accept cash for storage or transport fees, and we do not buy or sell metal, so this does not affect our clients directly. It does affect the wider market: dealers who previously sold bullion for cash above that level will need to move to bank transfer, and buyers should expect identity checks at lower thresholds than before.

Enhanced due diligence — the additional questions about the origin of wealth and the source of funds — will apply in more situations, including for clients connected to high-risk third countries and for politically exposed persons and their families. If you fall into one of these categories you may be asked to provide supporting documents such as sale contracts, inheritance papers or audited accounts when you open an account or when your holdings grow significantly. We will always explain why a document is needed.

Corporate and trust clients will see the beneficial-ownership rules tighten: ownership or control at 25 percent remains the threshold, but the Regulation requires more detail on control exercised through other means, and information will be cross-checked against national registers. Family offices holding metal through a company should make sure their register filings are current before onboarding.

From an operational point of view nothing changes to how your metal is stored or moved. Allocated, segregated custody, bar-level records and signed chain-of-custody documents are exactly what a regulator looks for when tracing the provenance of precious metals, and our portal already gives you and — with your consent — your auditor access to that record.

We will update our client agreement and privacy policy ahead of the July 2027 application date and notify all clients at least sixty days in advance. If you have questions about how the rules apply to your particular structure, our compliance team is happy to walk through it with you or your adviser.