AML5 / AML6 compliance for telco fintech.
Fifth (2018/843) and Sixth (2018/1673) Anti-Money Laundering Directives. Enforced from 2020-01-10 (AML5) / 2020-12-03 (AML6). Supervised by FIU (Financial Intelligence Unit) per member state + EBA AMLA from 2025. Coreal generates the evidence pack automatically on every Minctrl build — see /security-compliance for the full posture.
What this regulation covers.
Customer due diligence, beneficial-ownership transparency, predicate offence harmonisation (22 categories).
For a telco fintech, the salient angles are: BSS write-path protection (regulator must see read-only on event bus); Subscriber consent for fintech data sharing under GDPR; Group-level vs partner-bank capital allocation. Primary licence: Partner-bank EMI passport (or own EMI for tier-1).
- AML5 Art. 13 — Customer due diligence
- AML5 Art. 30 — Beneficial-ownership register
- AML6 Art. 3 — Predicate offences (incl. cybercrime, tax)
- AML6 Art. 7 — Corporate liability
What lands in the regulator file.
All items journaled, replayable, 7-year retention.
Which AML5 / AML6 articles apply to a telco?
Primarily: AML5 Art. 13 — Customer due diligence; AML5 Art. 30 — Beneficial-ownership register; AML6 Art. 3 — Predicate offences (incl. cybercrime, tax). The full mapping is in the Coreal compliance posture document — see /security-compliance.
What evidence does Coreal generate per audit?
KYC files (OCR + liveness + sanctions screen); Beneficial-ownership chain (for corporate customers); SAR (Suspicious Activity Report) filings + supporting journals. The Minctrl pipeline produces this artefact set automatically on every build — see /company §05 'How we ship'.
What are the penalties for non-compliance?
Up to €5M or 10% of turnover; AML6 introduces criminal liability for legal entities.
Bring the perimeter,
leave with a brief.
Read the Wave-1 runbook first.
The full 90-day launch sequence — phases, partner-bank gates, who signs off when. No form to read it.
Read the runbook →INDICATIVE DATA · Numbers and timelines reflect public regulator filings, vendor documentation and our own delivery experience. Per-engagement values vary with operator profile, BSS vintage and regulatory perimeter. Engage early for a fitted estimate under NDA.