The EU's anti-money-laundering rules for watch dealers from July 2027

A dealer in Munich can still take €14,500 in cash for a Daytona today, provided the buyer's passport is copied. The same sale in Amsterdam has been illegal since 1 January 2026. In Paris the cash limit is €1,000 for a French resident. On 10 July 2027 one regulation replaces all of that. The anti-money-laundering rules for watch dealers become the same in every member state, and for the first time a dealer is an “obliged entity” because of what they sell, not how they are paid.

The regulation is Regulation (EU) 2024/1624, the AMLR, adopted on 31 May 2024 and applying from 10 July 2027 (Article 90). It is a regulation, so it applies directly without national transposition. Its companion, Directive (EU) 2024/1640, covers supervisors and registers and has to be transposed by the same date. The new Anti-Money Laundering Authority, AMLA, sits in Frankfurt and is writing the technical standards that fill in the detail.

What a dealer has to do today

The current rules are national laws built on Directive (EU) 2015/849, the fourth directive as amended by the fifth. That directive pulls in “persons trading in goods” only when they accept or make cash payments of €10,000 or more. A dealer paid by bank transfer has no EU-level AML duties at all. Member states went further on their own, and the result is four different regimes in four neighboring markets.

In the Netherlands the Wet plan van aanpak witwassen has since 1 January 2026 banned professional traders in goods from accepting or making cash payments of €3,000 or more, in one payment or in linked payments. The trade-off, as the supervisor Bureau Financieel Toezicht sets out, is that ordinary goods dealers then fall out of the Wwft altogether: the client investigation, the reporting duty, the risk management, the training and the retention duty all lapse, leaving only the cash ban. Fines run to €10,000, doubled for repeat offenses. Dealers in art and cultural goods keep their due-diligence and reporting duties from €10,000 in any payment form. Watch dealers do not.

Germany has no general cash limit. Under § 10(6a) of the Geldwäschegesetz a Güterhändler must identify the customer for cash of €10,000 or more, and for cash of €2,000 or more where the goods are precious metals such as gold, silver and platinum, and file suspicious activity reports with the FIU (§ 10 GwG). Art objects are the exception to the cash framing: there the €10,000 trigger applies whatever the payment method. France caps cash paid to a professional at €1,000 where the buyer is tax-resident in France or acting for professional purposes. A buyer who can show they are not tax-resident in France and is not acting professionally may pay up to €15,000 in cash, but only where the seller is itself on the list of AML-obliged businesses in Article L561-2; otherwise the ceiling for that buyer is €10,000. Fines run up to 5% of the sum paid, split between payer and payee (Article D112-3 of the Code monétaire et financier, service-public.gouv.fr). Italy has held its limit at €5,000 since 1 January 2023 under Article 49, paragraph 3-bis of Legislative Decree 231/2007, raised from €2,000 by the 2023 budget law and unchanged since (Camera dei Deputati, Money.it).

Who is an obliged entity from 10 July 2027

The AMLR drops the old “cash of €10,000” test for goods traders and replaces it with a list. Article 3(3)(e) covers persons trading in precious metals and stones, and Article 3(3)(f) persons trading in high-value goods, in both cases where they do so “as a regular or principal professional activity”. High-value goods are defined in Annex IV: jewelry, gold- or silversmith articles, and clocks and watches “of a value exceeding EUR 10 000”; motor vehicles above €250,000; aircraft and watercraft above €7,500,000 (Better Regulation, Annex IV, amlr.eu, Article 3). The thresholds are values exceeded, so a watch at exactly €10,000 is below the line. Recital 18 says plainly that other persons trading in goods “no longer need to be subject to AML/CFT obligations, with the exception of persons trading in precious metals, precious stones, other high value goods and cultural goods”.

A dealer whose regular business includes watches over €10,000 is therefore an obliged entity from July 2027 whatever the payment method. Payment method stops deciding scope and decides only thresholds. A dealer who sells nothing above €10,000 stays outside, subject only to the cash limit in Article 80. The regulation does not say how many €10,000-plus sales make the activity “regular”; that reading will come from national supervisors and AMLA guidance. A gold case also raises the question of whether a watch dealer is trading in precious metals under point (e) as well as high-value goods under point (f). The text does not answer it, and the cautious reading is that the duties are the same either way.

The cash limit

Article 80(1) is one sentence: 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” (Better Regulation, Article 80). The limit does not apply to payments between private individuals who are not acting professionally, or to deposits at a bank.

Two further paragraphs keep the map uneven. Under Article 80(2) a member state may adopt a lower limit after consulting the European Central Bank. Under Article 80(3) limits that already exist below €10,000 “shall continue to apply”. So on 10 July 2027 the Dutch €3,000, the French €1,000 and the Italian €5,000 stay in force, and Germany, which has none, gets €10,000. The regulation does not say which limit governs a cross-border sale; the practical reading is the limit of the country where the cash changes hands, and a dealer should not rely on that without advice.

Regular describes the dealer, occasional describes the customer

Two words in this regulation sound like they measure the same thing and do not.

“As a regular or principal professional activity” is the phrase in Article 3(3) that decides whether a business is in scope at all. It describes the dealer. A shop that buys and sells watches over €10,000 as part of what it does is in; a furniture dealer who takes one watch in part-exchange is not. The regulation never defines “regular”, which is why that line will be drawn by national supervisors rather than by the text.

“Occasional transaction” describes the customer, and it does not mean rare. It is the residual category: any transaction that is not part of a business relationship. Article 2(19) defines a business relationship as one “expected to have, at the time when the contact is established, or which subsequently acquires, an element of repetition or duration”. A stranger who walks in, buys a watch and leaves is an occasional transaction however busy the shop is. Forty of them in a month are still forty occasional transactions.

Which of the two it is decides which rule applies, and the thresholds below only ever attach to the occasional kind. A collector who opens an account, leaves a wishlist and comes back twice a year has moved from one column to the other.

The third word is “linked”. Article 2(20) covers “two or more transactions with either identical or similar origin, destination and purpose, or other relevant characteristics, over a specific period”, which is what stops a €14,500 watch becoming three payments of €4,833. AMLA's draft standards under Article 19(9), due in final form in the third quarter of 2026, list the markers to weigh: the same person or their family, business partners, customers acting in concert, a shared IP address or device, one invoice paid in instalments. Their numeric repetition tests, three transactions in a rolling 12 months, are written for currency exchange, remittance and crypto rather than for goods traders (AMLA, anti-money-laundering.eu).

What customer due diligence means for a sale

Article 19 sets four triggers: establishing a business relationship, carrying out “an occasional transaction of a value of at least EUR 10 000” in one or several linked operations, suspecting money laundering at any amount, and doubting data already held (Better Regulation, Article 19). Only the second carries a threshold. Opening a business relationship triggers due diligence whatever the first watch costs.

Cash has its own lower line. Article 19(4) requires the dealer to apply “at least” the measure in Article 20(1)(a), identifying the customer and verifying their identity, for an occasional transaction in cash of €3,000 or more (amlr.eu, Article 19). That is a reduced form of due diligence: identify and verify the customer, without the beneficial-ownership step or the assessment of purpose that a €10,000 transaction brings.

Full due diligence under Article 20 has four parts: identify the customer and verify identity; identify the beneficial owner of a corporate customer and take reasonable measures to verify; understand the purpose and intended nature of the relationship or transaction; and monitor the relationship on an ongoing basis. The beneficial-ownership threshold is 25% of shares, voting rights or other ownership interest, held directly or indirectly (Article 52(1)). It can fall, but not at a member state's discretion: under Article 52(2) the Commission may set lower thresholds for higher-risk categories by delegated act before 10 July 2029, capped at 15% unless the risk justifies more (Better Regulation, Article 52).

Article 69 requires a report to the national FIU, on the dealer's own initiative, wherever the dealer “knows, suspects or has reasonable grounds to suspect” that funds are criminal proceeds, regardless of amount. FIU information requests are answered within five working days (Better Regulation, Article 69). Article 77(3) requires the due-diligence file and the transaction records, including any report, to be kept for five years from the end of the relationship, the completion of the occasional transaction or a refusal to deal, with a case-by-case extension of up to five more years if a competent authority asks (Better Regulation, Article 77).

One sale, four cities, before and after

The worked example is a Rolex Daytona ref. 126500LN sold to a private buyer for €14,500, with the buyer offering cash. “Today” is 21 August 2026.

A €14,500 Daytona, four cities, before and after 10 July 2027

Amsterdam today: Maximum cash accepted €2,999. The dealer is not an obliged entity. No due diligence on a sale by transfer. A €3,500 cash deposit is an illegal payment. No retention duty and no report route.
Amsterdam from 10 July 2027: Maximum cash accepted €2,999, the national limit kept under Article 80(3). Obliged entity under Article 3(3) and Annex IV. Due diligence on this sale by transfer, as a €10,000 occasional transaction under Article 19(1)(b). A €3,500 cash deposit remains an illegal payment. Records kept five years under Article 77. Reports go to FIU-Nederland under Article 69.
Munich today: No cash limit, identification at €10,000. Obliged entity as a Güterhändler under the GwG. No due diligence on a sale by transfer. No due diligence on a €3,500 cash deposit, which is below €10,000. Records kept five years under the GwG. Reports go to FIU Deutschland.
Munich from 10 July 2027: Maximum cash accepted €10,000 under Article 80(1). Obliged entity. Due diligence on this sale by transfer. A €3,500 cash deposit requires identifying and verifying the buyer under Article 19(4). Records kept five years. Reports go to FIU Deutschland.
Paris, a French-resident buyer, today and 2027: Maximum cash accepted €1,000. Obliged entity under the Code monétaire et financier. National rules govern due diligence today. A €3,500 cash deposit is an illegal payment. Records kept five years. Reports go to Tracfin.
Milan, today and 2027: Maximum cash accepted €4,999. Obliged entity under D.Lgs. 231/2007. National rules govern due diligence today. A €3,500 cash deposit requires identifying and verifying the buyer. Records kept five years. Reports go to UIF.

Two lines in that comparison are still open. The French and Italian due-diligence entries describe current transposition of the directive; from 10 July 2027 the AMLR's triggers apply directly there too, and the national cash limits carry on underneath. And the Dutch entry assumes the government keeps the €3,000 limit, which the finance minister defended in parliamentary answers of 3 March 2026, refusing sector exemptions and allowing cash above the limit only for purchases by Dutch traders outside the EU.

What the file for a €10,000-plus sale contains

The regulation describes duties, not paperwork. A file that meets Articles 20 and 77 for a single €14,500 sale to a private buyer is short. It holds a copy of a government identity document, the date it was checked and the name of the staff member who checked it, and the buyer's residential address. For a company buyer it adds the register extract and the identity of each beneficial owner at 25% or more, checked against the national beneficial-ownership register. It records the purpose of the transaction in one line, which for a retail watch sale is the sale itself. It keeps the invoice with the serial number on it, and the payment record showing the method and, for cash, the amount and date of each tranche. If anything stood out, such as a buyer paying for several watches in separate visits or declining to give a reason for cash, the internal risk note goes in too. Where a report went to the FIU, so does a copy of it and the assessment behind it. The same file is kept for a refused sale. Five years, then the personal data is deleted unless another law says otherwise.

For the dealer-to-dealer trade the counterparty is a business, and the beneficial-owner step is the one most often skipped. A register extract and a list of owners at 25% takes 10 minutes and is the difference between a complete file and an incomplete one at inspection.

What is still being written

Two things a dealer will need do not exist yet. Supervision stays national, so the authority a watch dealer registers with, and the penalties it can impose, come from national law transposing Directive 2024/1640, due by 10 July 2027. And the due-diligence standards under Article 28 are on the same timetable as the Article 19(9) standards above. The file structure can be built now on the regulation's own text; the thresholds will hold.

FAQ

I only sell by bank transfer. Do these rules apply to me? From 10 July 2027, yes, if selling watches over €10,000 is a regular part of the business. Scope is decided by the goods in Annex IV, not by the payment method.

What is the difference between a regular activity and an occasional transaction? “Regular” describes the dealer and decides whether the rules apply to the business at all. “Occasional” describes a customer who is not in an ongoing relationship with the shop, and decides which due-diligence trigger applies to that sale. A busy dealer is regular, and most of that dealer's sales are still occasional transactions.

Can I take €9,000 in cash for a watch in 2027? In Germany, yes, with identification and verification of the buyer because the sum is above €3,000. In the Netherlands, France and Italy, no: the lower national limits stay in force under Article 80(3).

Does a €7,000 watch trigger due diligence? Not as an occasional transaction paid by transfer; the trigger is €10,000. Paid in cash of €3,000 or more, the buyer must be identified and verified under Article 19(4), and any suspicion triggers a report at any amount.

What happens to the Dutch rule that took watch dealers out of the Wwft? It lasts until 9 July 2027. From 10 July the AMLR applies directly, and a Dutch dealer regularly selling watches over €10,000 is an obliged entity again, with the €3,000 cash ban on top.