CJEU confirms direct liability of legal persons under EU AML/CFT rules

In its recent judgment (Case C 291/24) of 29 January 2026 (“CJEU Judgment”), the Court of Justice of the European Union (“CJEU”) addressed a key issue in applying the EU anti-money laundering and counter-terrorist financing (“AML/CFT”) framework: whether Member States may impose additional requirements relating to sanctions on legal persons under national law. The CJEU Judgment is particularly important for obliged entities. It confirms that legal persons can be held liable for breaches of AML/CFT obligations and that national rules cannot make such liability conditional on requirements that undermine the effectiveness of the sanction rules set out in Directive (EU) 2015/849. This reasoning is also expected to apply under Regulation (EU) 2024/1624, which will replace Directive (EU) 2015/849.

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