Changes to the AML Package – is the yachting industry facing a revolution? 

It is the middle of summer 2027. You are a broker/dealer and are just finalising the sale of a yacht worth 8,000,000 euros to a client from Dubai. The client is paying by bank transfer. As usual, you check the documents, but…

…this time, you must report the entire transaction to the General Inspector of Financial Information (GIIF), gather full UBO documentation, ascertain the sources of the client’s funds and assets, and carry out what is known as enhanced due diligence. You must do this before signing the contract. 

The bank will also report the transaction to the GIIF. 

And if you fail to do so, you could face a fine. 

From 10 July 2027, this is exactly how the sale of superyachts will work across the European Union. 

In recent years, the yachting industry has been subject to strict supervision. However, the obligations of buyers and brokers have focused on limiting cash transactions. 

That is now coming to an end. 

In 2027, the AMLR Regulation will come into force. It will introduce uniform, directly applicable rules for the entire market. Many of the changes will affect, amongst other things, high-value goods. But is that all? In our view, the changes may not be limited to them alone. 

What will change 

The new regulations will introduce two main changes: 

1. direct obligations for those trading in high-value goods (vehicles worth over 250, 000 EUR, yachts worth over 7, 500, 000 EUR),
2. indirect obligations for the entire yachting industry. 

The obliged entity will be a person trading in high-value goods as part of their usual or core professional activities. 

This means that the obliged entity will be a broker or dealer who offers (even occasionally) yachts worth over 7, 500, 000 EUR. 

Direct obligations: 

When selling high-value yachts for non-commercial purposes, a broker or dealer will be required to: 

• report the transaction to the GIIF,
• carry out full due diligence, including verifying the source of the buyer’s funds and assets. 

Indirect obligations: 

Although the regulations explicitly refer to vessels costing more than EUR 7,500,000, we cannot rule out the possibility that, after 10 July 2027, the entire yachting industry will be classified as a high-risk sector. 

The regulation contains the following information: 

Motor vehicles, vessels and aircraft in the higher market segments are exposed to the risk of being misused for money laundering and terrorist financing due to their high value and the fact that they are suitable for transport. 

This provision alone does not broaden the definition of vessels as “high-value goods”. However, given that banks have hitherto assessed each transaction for money laundering and terrorist financing risks, such a provision in the regulation could result in the entire industry being classified as high-risk in the upper sector, i.e. regardless of the value of the yacht. 

Three market segments – how the changes will affect you 

After 10 July 2027, the yacht market will be divided into three segments: 

1. superyachts,
2. mid-range yachts,
3. small yachts. 

Summary 

From 10 July 2027, the most significant changes will affect brokers/dealers of superyachts valued at over 7.5 million EUR. They will become obliged entities and will be subject to a number of new obligations. 

In addition, transactions involving yachts valued at over 7.5 million EUR will be subject to reporting (by both the broker/dealer and the bank). 

However, the entire industry may feel the effects of the banks’ stricter policies. Yacht transactions will be regarded as high-risk transactions. For your clients, this means having to prepare a much larger volume of documentation. As a broker or dealer, you will need to take this into account when structuring transactions and assessing when a contract might be finalised. 

This shouldn’t be a significant change for small and medium-sized brokers, but it’s certainly worth factoring it into your business model now. Especially if you’re targeting the sale of higher-value yachts. 

In the next articles in this series, we’ll break the topic down into its constituent parts and answer the following questions: 

• exactly who will be considered an obliged entity,
• what obligations will apply to obliged entities, and what obligations will apply to other brokers,
• what additional obligations will arise when selling a yacht exceeding the price limit,
• what due diligence and cooperation with banks will look like in practice,
• how to prepare your company for the new reality. 

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