The current EU rules on anti-money laundering and countering the financing of terrorism (AML/CFT) apply to insurance intermediaries where they act with respect to life insurance and other investment-related services and to investment firms. In line with the current framework, only those insurance intermediaries fall within the scope of the revised EU’s legislative package and must comply with the AML/CFT requirements. Insurance intermediaries pursuing insurance distribution in relation to non-life insurance products remain outside the scope.

The revised EU’s legislative package also maintains the current exemption for insurance intermediaries which engage in the distribution of life-insurance and investment-related insurance products, but: (i) act under the responsibility of one or more insurance undertakings or intermediaries; and (ii) do not collect premiums or amounts intended for the customer.

The revised EU’s legislative package introduces AML/CFT requirements for consumer and mortgage credit intermediaries that hold funds (i.e. banknotes and coins, scriptural money, or electronic money) in connection with credit agreements. Those who operate under the responsibility of one or more creditors or other credit intermediaries are not subject to the revised EU’s legislative package.

In line with the current framework, the revised EU’s legislative package also applies to investment firms, as defined in the MiFID II Directive. As a general rule, all financial intermediaries that meet the definition of an investment firm within the meaning of the MiFID II Directive, including those that pursue activities under the so-called “opt-out” regime, are subject to the revised rules.

(Last updated in June 2026)

BIPAR-Steptoe Handbook on the new AML/CFT framework for insurance, credit, and financial intermediaries

The new EU’s legislative package aimed at strengthening the EU framework on AML/CFT will apply from July 2027.  The revised EU AML/CFT framework will require in-scope insurance, financial and credit intermediaries to take additional actions to maintain effective compliance.

The intermediary sector takes the AML/CFT seriously. BIPAR commissioned the Brussels office of Steptoe LLP to draw up a handbook which aims to help associations of in-scope intermediaries and the intermediaries themselves to navigate the requirements of the new AML/CFT framework.

Responsibility for compliance with all relevant EU and national legislation rests with individual firms and we hope that this handbook will encourage market participants, and national regulators and supervisory authorities, to continue building together a realistic and efficient framework and system of AML/CFT.

This handbook is up to date as per March 2025 and does not yet cover the Level 2 or Level 3 more detailed rules. 

We thank the authors, Guy Soussan, Partner, and Algirdas Semeta, Legal Consultant, for their fruitful work and Isabelle Audigier, BIPAR Legal Director, and Rebekka De Nie, EU Policy Manager, who led BIPAR participation in this work.

(September 2025)