The Latvian statute's dated 2027 version changes almost nothing, which is what happens when a Directive is replaced by a Regulation. Three instruments, two deadlines that have already passed, and one date after which the obligation is governed by the Regulation and only the institutional framework stays national.
Latvia's anti-money-laundering law carries a dated future version on the official register, taking effect on 10 July 2027. It looks like the moment the Latvian regime is rewritten for the EU package. It is not: that text changes a single sentence, about how state institutions pass information to the Financial Intelligence Service, and nothing in it touches obliged entities.
One qualification matters, though, and it is easy to miss: that is true of the 2027 text specifically. The version of the Latvian law in force already carries part of the new Directive.
Three instruments, not one
Regulation (EU) 2024/1624 (AMLR) — the substantive rulebook: obliged entities, due diligence, beneficial ownership, reporting. Directly applicable from 10 July 2027. No Latvian act is needed, and none can contradict it.
Directive (EU) 2024/1640 (AMLD6) — supervisors, registers and FIU powers. Requires Latvian legislation, with deadlines both earlier and later than 2027.
Regulation (EU) 2024/1620 — the EU Anti-Money Laundering Authority, applying since 1 July 2025.
Today's Latvian obligations exist because Latvia transposed Directive (EU) 2015/849, which is repealed from 10 July 2027. After that, the operative text for most of what a compliance officer does is an EU instrument, read directly.
Two deadlines have already passed
AMLD6 required Article 74 by 10 July 2025, and Articles 11, 12, 13 and 15 — access to beneficial ownership registers — by 10 July 2026.
Latvia has transposed part of that. The law amending the AML Law adopted on 3 December 2025 transposes Article 12, the expanded beneficial ownership data, applied by the Enterprise Register since 5 October 2026, and Article 15, restricted access on application, in force from 1 July 2026. Both sit in the version now in force, not in the 2027 redaction.
The position on Articles 11 and 13, the legitimate-interest access regime, is not settled on the public record, and Article 74 is in the same position. Those are questions for Latvian counsel, not matters to infer.
Businesses caught for the first time
Article 3 of the AMLR sets the list directly, and several categories will be unfamiliar to anyone reading only the Latvian law today:
crowdfunding service providers and intermediaries;
credit intermediaries for mortgage and consumer credit;
investment migration operators — residence rights in exchange for investment;
football agents, and professional clubs for transfers and dealings with investors, sponsors and agents;
dealers in cultural goods, and estate agents including lettings, at EUR 10,000 or more.
If your business is on that list, the question is not what the Regulation will say in 2027 but how long a control system takes to build from nothing — months, not weeks.
Beneficial ownership: the same number, a different test
The figure of 25 % appears in both regimes, which makes it easy to read across. It should not be. The Latvian definition turns on a holding of more than 25 %; under Article 52(1) of the Regulation an ownership interest means 25 % or more. A shareholder holding exactly a quarter is outside the Latvian definition and inside the Regulation's — one word that changes who must be identified and registered.
Two further points are often missed. Control is tested in parallel, not as a fallback: Article 51 requires control by other means to be identified independently of any ownership interest, which is not the cascade many internal procedures still describe. And the 25 % can be lowered for higher-risk sectors by delegated act, capped at 15 % or a higher figure justified by risk but in any case below 25 %. No such act has been adopted. The Commission has until 10 July 2029 to assess the categories Member States notify. The 15 % is the ceiling on that power, not a floor.
Separately, Article 80 caps cash payments for goods or services at EUR 10,000. Do not read it against the Latvian rule where EUR 10,000 is the threshold at which a trader becomes an obliged entity: the figures coincide, the effects do not. One brings you into the regime, the other caps the transaction.
Which law you will be reading after July 2027
From 10 July 2027 the Regulation, not the Latvian law, governs who is an obliged entity and what due diligence, beneficial ownership, reporting and record-keeping require. Latvian provisions on those matters will be displaced even if they remain on the statute book. What stays national is the institutional framework: who supervises, what sanctions apply, the FIU's powers and the beneficial ownership register.
For a compliance manual the consequence is practical: cite the Regulation for the obligation and Latvian law only for the institutional framework. A procedure written as a paraphrase of Latvian section numbers ages badly once its parent Directive is repealed. A documented risk assessment transfers cleanly, because both regimes require it.
No draft law repealing or restructuring the Latvian AML Law has been published; Latvia is adapting by amendment. One point is not yet answerable: several Latvian obliged-entity categories — debt recovery providers, insolvency administrators, cash collection providers — do not appear in Article 3, and their position after July 2027 turns on whether Latvia extends scope nationally.
If your business is newly caught, or you are working out which parts of your framework survive 10 July 2027 unchanged, our AML team advises on exactly this. Get in touch.