The 2027 version of the Latvian AML law changes one sentence, which is not the rewrite everyone expects. The real change is that from 10 July 2027 an EU regulation decides what you have to do, and Latvian law only decides who supervises you.
Latvia's anti-money-laundering law has a future version sitting on the official register, dated 10 July 2027. It looks like the day the Latvian rules get rewritten for the new EU package. It is not. That version changes one sentence, about how state institutions pass information to the Financial Intelligence Service. Nothing in it affects the businesses the law applies to.
One thing is easy to miss here. That is true of the 2027 text only. The version of the Latvian law in force today already contains part of the new EU Directive.
There are three EU laws, not one
People talk about “the AML package” as if it were one document. It is three, and they work in different ways.
The AML Regulation (EU 2024/1624). This is the rulebook: who the rules apply to, how you check your clients, beneficial owners, reporting, record-keeping. It applies directly from 10 July 2027. Latvia does not need to pass anything for it to work, and cannot pass anything that contradicts it.
The sixth AML Directive (EU 2024/1640). This one is about supervisors, registers and the powers of the Financial Intelligence Unit. It does need Latvian legislation, and its deadlines fall both before and after 2027.
The Regulation setting up the EU's new AML Authority (EU 2024/1620), which has been running since 1 July 2025.
Everything a Latvian business does today comes from an older EU directive, from 2015. That directive is repealed on 10 July 2027. After that date, most of what a compliance officer works with is an EU text read directly, not a Latvian one.
Two deadlines have already gone by
The Directive gave Latvia until 10 July 2025 for one article, and until 10 July 2026 for the rules on who can look at beneficial ownership registers.
Part of that is done. A law amending the Latvian AML Law, adopted on 3 December 2025, brought in the expanded beneficial ownership data — which the Enterprise Register has been applying since 5 October 2026 — and the rules on restricting access to that information, in force since 1 July 2026. Both are in the version of the law in force now, not in the 2027 one.
Two pieces are not settled on the public record: Articles 11 and 13, about who has a legitimate interest in seeing register data and how that is checked, and Article 74. These are questions to put to Latvian counsel rather than guess at.
Businesses that will be covered for the first time
The Regulation lists who it applies to, and several of them are not on the Latvian list today:
crowdfunding platforms and intermediaries;
credit intermediaries for mortgages and consumer loans;
firms running investment migration programmes — residence in exchange for investment;
football agents, and professional clubs, for transfers and for dealings with investors, sponsors and agents;
dealers in cultural goods, and estate agents including letting agents, from EUR 10,000.
If your business is on that list, the useful question is not what the rules will say in 2027. It is how long it takes to build a compliance system from nothing. The answer is months, not weeks.
Beneficial owners: same number, different test
Both regimes use 25 %, which makes it tempting to assume nothing changes. It does. The Latvian definition catches someone holding more than 25 %. The Regulation catches an ownership interest of 25 % or more. So a shareholder with exactly a quarter is outside the Latvian rule and inside the EU one. One word, and a different list of people you have to identify and register.
Two further points get missed often.
Control is checked alongside ownership, not after it. Control by other means has to be identified on its own, whatever the shareholding is. Many internal procedures still describe a cascade — look at ownership first, fall back to control — and that is not what the Regulation asks for.
The 25 % can be lowered for higher-risk sectors, by a separate EU act, to no lower than 15 %. No such act has been adopted. The Commission has until 10 July 2029 to look at the categories Member States put forward. So 15 % is the lowest the figure could go — a limit on the power, not a floor that anyone has to plan around today.
One more figure worth keeping apart from the Latvian one: the Regulation caps cash payments for goods or services at EUR 10,000. The Latvian EUR 10,000 is different — it is the point at which a trader becomes subject to the AML rules. The numbers match, the effects do not. One brings you into the system; the other limits a single payment.
Which law you will be reading after July 2027
From 10 July 2027 the Regulation decides who is covered, and what client checks, beneficial ownership, reporting and record-keeping require. Latvian rules on those subjects will be displaced even if they remain on the statute book. What stays Latvian is the structure around it: who supervises you, what penalties apply, what the Financial Intelligence Service can do, and the beneficial ownership register.
For a compliance manual that means one simple habit. Cite the Regulation for the obligation, and Latvian law only for the structure. A procedure written as a retelling of Latvian section numbers will age badly once the directive behind them is gone. A documented risk assessment carries over without trouble, because both regimes require one.
No draft law rewriting the Latvian AML Law has been published; Latvia is adapting it piece by piece. One question has no answer yet. A few categories that are covered in Latvia — debt recovery firms, insolvency administrators, cash collection companies — are not on the EU list, and what happens to them after July 2027 depends on whether Latvia keeps them covered nationally.
If your business is newly covered, 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.