Navigating Regulation: European Yachting Faces Stricter Anti Money Laundering Rules

The yachting sector is preparing for a major regulatory shift. From 10 July 2027, a new European regulation aimed at strengthening the prevention of money laundering and terrorist financing will come into force. We spoke with Ezio Dal Maso, partner, and Blanche Balian, of counsel, at the law firm Stephenson Harwood, to understand how this framework will affect the market and which practical measures industry professionals will need to adopt.

PM: What are the main AML/CFT obligations under the new regulation for yachting?

Dal Maso: The regulation introduces clear and systematic obligations for yachting professionals involved in the marketing of high‑value assets, in particular yachts valued over €7.5 million¹. Among the key changes, all “Professional Dealers” and “High‑Value Goods Intermediaries” will need to implement internal compliance systems, conduct thorough due diligence on clients and suppliers, report suspicious transactions, and establish appropriate compliance governance².

Balian: It is important to emphasize that the regulation replaces previous directives with a text directly applicable across all Member States³. This means there will no longer be differences between countries: the same rules will apply throughout the EU, and professionals must prepare in advance to avoid legal, financial, and reputational risks.

PM: How do the rules for reporting high‑value transactions change?

Balian: One of the most significant changes concerns transactions involving assets purchased for private purposes. Specifically, all sales of yachts over €7.5 million must be reported to the Financial Intelligence Units (FIUs), in France, Tracfin, regardless of any suspicion of money laundering⁴. This reporting requirement is threshold‑based, not suspicion‑based, for certain high‑value goods like watercraft, which are listed in Annex IV of the regulation⁵.

Dal Maso: It is crucial to understand that these are no longer “suspicious” reports. Even in the absence of risk indicators, reporting is mandatory and systematic. This approach represents a break from traditional practice and requires professionals to update internal systems and operational procedures to ensure full traceability of transactions.

PM: What do the transparency obligations regarding beneficial ownership entail?

Dal Maso: The regulation requires non‑EU legal entities to provide information on their beneficial owners when entering into business relationships with entities classified as medium‑high or high risk, or when purchasing high‑value yachts⁵. This information must be registered in the central registers of Member States, accompanied by supporting documentation, before the start of the business relationship or the completion of the purchase.

Balian: In practice, even non‑EU clients must ensure transparency regarding their corporate structure and ultimate beneficiaries. Obligated Entities have the responsibility to inform their clients of these obligations and to request proof that registration has been completed.

PM: What penalties are envisaged for non‑compliance?

Dal Maso: The regulation leaves it to Member States to determine penalties, which must be “effective, proportionate, and dissuasive”³. The European Commission will define, by July 2026, categories of violations, severity indicators, and criteria for calculating penalties. Beyond possible fines, non-compliance can entail legal and financial risks, including criminal liability for facilitating money-laundering transactions.

PM: What practical recommendations do you have for yachting operators?

Balian: As the regulation will come into force in about a year and a half, operators should immediately assess whether they fall within its scope and begin implementing adequate internal measures. This means updating due diligence procedures, reporting systems, and staff training.

Dal Maso: The key is to anticipate the change. Those who act promptly will be able to mitigate risks while also enhancing their reputation as transparent and reliable operators in the international yachting market.

The new European regulation thus represents a turning point for the sector, driving greater responsibility and transparency. For yachting professionals, preparation and adaptation of internal procedures are no longer optional, they are a strategic obligation for safely navigating the European market.

Filippo Ceragioli

 

Footnotes

¹ Article 74 of the EU Anti‑Money Laundering Regulation (AMLR) requires that persons trading in high‑value goods report to the Financial Intelligence Unit (FIU) all transactions involving specific high‑value goods acquired for non‑commercial purposes, including watercraft priced at €7,500,000 or more. (springlex.eu)

² Professional Dealers and High-Value Goods Intermediaries are required to implement internal compliance systems, conduct due diligence, report suspicious transactions, and establish governance to ensure compliance. (anti-money-laundering.eu)

³ The regulation is directly applicable across all EU Member States, replacing previous directives and ensuring uniform rules on AML/CFT obligations, including sanctions for non-compliance. (investmentpolicy.unctad.org)

⁴ All high-value transactions above thresholds must be reported to FIUs (e.g., Tracfin in France) systematically, even in the absence of suspicion. (service.betterregulation.com)

⁵ Non-EU entities must provide beneficial ownership information for high-risk transactions, registered in the central registers of Member States before initiating business or completing purchases. (eur-lex.europa.eu)

 

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