Luxury Cars 2027 – AMLR, the €250,000 Threshold, Customer Due Diligence and Reporting Log | Word/PDF/Excel

AMLR for Exclusive Cars 2027 – customer due diligence, threshold amounts and secure decision-making in transactions involving high-value motor vehicles. The EU's new anti-money laundering regulation (EU) 2024/1624 will generally apply from 10 July 2027. It covers, among others, persons who regularly or as their main professional activity trade in high-value goods. For certain sales of motor vehicles for non-commercial purposes, there is also special threshold-based reporting under Article 74. This document package is tailored for Swedish car dealers who need to assess the rules for specific transactions.

Quick facts: 7 editable Word (DOCX) files + 7 corresponding searchable PDFs + 1 Excel (XLSX) file with nine tabs = 15 files in a digital ZIP. Five Swedish operational templates, a Swedish user guide and a separate English User Guide. The Swedish forms are not available as full English translations. The PDF files are printable and searchable, not digitally fillable.

Who Can Benefit Practically from the Product?

Swedish dealers of exclusive cars, companies that mainly or regularly trade in particularly high-value motor vehicles, importers who sell exclusive cars, finance managers, AML/compliance officers and internal auditors. The product is not intended for private individuals who only want to draw up a purchase agreement for a standard passenger car.

Two Different €250,000 Thresholds – The Crucial Detail

Annex IV to AMLR defines high-value motor vehicles using the wording price exceeding €250,000 or the equivalent amount in national currency. This is relevant to the dealer's status under Article 3.3(f). However, Article 74.1(a) uses the wording at least €250,000 for certain threshold-based reports when vehicles are acquired for non-commercial purposes. The wordings should not be confused.

Especially at exactly €250,000: Annex IV uses "exceeding", while Article 74 uses "at least". A borderline case requires a qualified manual assessment of the scope of the business, Article 3, applicable rules and the actual transaction circumstances. The package flags the case for investigation – it does not grant an automatic exemption or automatic reporting obligation.

If the purchase price is in SEK, an actual and documented relevant exchange rate and its date must be assessed. Excel supports calculating a preliminary euro amount from a rate entered by the user. It does not fetch live rates or determine the legally correct rate.

Article 74 – Special Report to the Financial Intelligence Unit

According to Article 74.1(a), the relevant persons shall report the sale of high-value motor vehicles to the financial intelligence unit when the conditions are met, including the price being at least €250,000 and the purchase being for non-commercial purposes. Article 74.3 refers to deadlines established by the financial intelligence unit. The official Swedish channel, format and deadline for this special reporting must be verified when actually applied in 2027. The accompanying templates are not official reporting forms.

It is important to understand that a threshold report under Article 74 does not require suspicion in the same way as suspicion reporting under Article 69. Even suspicions below the threshold amount may be covered by other rules. A business must not disclose to the customer that such a suspicion report is planned or made when Article 73 applies.

Article 67 – Special Case When the Buyer is a Company Outside the EU

Article 67 contains provisions on the registration of the beneficial owner for certain legal persons established outside the EU and certain equivalent foreign arrangements. In some situations, this includes a temporary acquisition of high-value motor vehicles for non-commercial purposes. Article 67 is not a general additional registration requirement for every foreign private individual, Swedish legal person or vehicle transaction. Document 05 helps the car dealer investigate what actual buyer role and registration situation exists.

Complete File List – What Is Included?

Excel with Nine Tabs and 894 Formulas

Start: overview, key figures and legal warnings. Transactions: internal case ID, vehicle ID and currency conversion. Classification: dealer role and separate flags for Annex IV and Article 74. Customer Due Diligence: protected evidence references for identity, beneficial owner, PEP and financing. Payments: transaction chain and account change. Art 74: assessment of threshold and non-commercial purpose. Art 67: special assessment of non-EU buyer. Deviations: stop, completion and responsible case officer. Sources: links to official legal sources.

The formulas provide administrative flags: Missing documentation, Documentation recorded – MANUAL ASSESSMENT or amount flags that specifically mark exactly €250,000. Three types of tests have been carried out with fictitious internal case IDs: the threshold limit, complete fields and removed control fields. The test data is not included in the customer version and the start page shows zero cases.

Three Concrete Business Situations

1. Car for private use for €275,000. The dealer documents their business status, customer due diligence and whether Article 74 should be assessed separately from any suspicion.
2. Purchase price exactly €250,000. The seller sees that Annex IV uses "exceeding", Article 74 "at least" and sends the borderline case to the person responsible for legal assessment before a reporting decision.
3. Company established outside the EU buys a car for €300,000 for non-commercial purposes. The business checks any Article 67 requirements, ownership structure and actual buyer role as well as payment chain and Article 74.

Step-by-Step: How the Documents Are Used

1. Register a pseudonym internal business reference and document whether the company is a relevant professional trader under Article 3.3(f).
2. Assess the amount in EUR with a verifiable rate reference and note whether the purpose is commercial or non-commercial.
3. Perform actual KYC checks in an authorization-controlled system. Link only document references to the templates.
4. Check third-party payments, changed accounts, representatives, beneficial owner and risk indicators.
5. Assess Article 74, Article 69 and any Article 67 separately. Do not use the Excel status as the final decision.
6. Document the responsible case officer's decision, any pause, secure FIU receipt and the next control point.

GDPR, Information Security and Confidentiality

The accompanying templates are designed for masked vehicle references, internal customer/business IDs and secure document references. Full ID documents, personal identity numbers, account numbers, sensitive personal data and actual FIU reports should not be placed in this Excel workbook. Handle real AML data in authorization-controlled systems in accordance with GDPR and applicable sector rules. The Swedish Financial Police currently use goAML for suspicion reporting. The package does not send any authority reports and must not be used to circumvent reporting obligations.

Frequently Asked Questions

Will AMLR apply to luxury car transactions during 2026?

The regulation will generally apply from 10 July 2027. Swedish anti-money laundering rules may, however, apply to certain businesses earlier. Assess the actual roles and subsequent national/European changes.

Is a car for exactly €250,000 a reportable transaction?

Article 74 uses "at least €250,000" and Annex IV uses "exceeding €250,000". The exact borderline case must be analyzed against the dealer's status under Article 3 and the entire regulatory framework; the template flags the need for legal assessment, not an automatic yes or no.

Must the car dealer report every car over €250,000?

Not automatically. Article 74 is linked to the relevant persons, price and the acquisition of the goods for non-commercial purposes. Suspicion reporting may separately be required under other provisions regardless of the amount.

Is a threshold report under Article 74 the same as a suspicion report?

No. Threshold reporting and suspicion reporting under Article 69 have different conditions. Also keep reporting confidentiality and the relevant channels separate.

Can Excel automatically calculate the current euro amount from kronor?

It can calculate based on a rate that the user themselves enters and documents. It does not fetch an exchange rate and does not automatically select which day or rate should legally be used.

Does Article 67 apply to all foreign buyers?

No. The article applies to special situations for legal persons established outside the EU and certain arrangements. It does not automatically cover all foreign private individuals.

Can I put passport copies and actual FIU reports in the Excel file?

No. Use only administrative evidence references and store such data in a separate secure and authorization-controlled system.

Are the templates approved by the Swedish Financial Police or a lawyer?

No. It is a practical preparation tool with AI-assisted source control. It is not an official FIU form, authority certification or independent legal review.

Related Mallbutiken Products

For broader processes around money laundering, PEP and customer due diligence, there is AML/KYC & Anti-Money Laundering Compliance. For the purchase transaction itself, there is, for example, Car Purchase Agreement – Private Individual. This package is instead limited to the business's AMLR control of high-value motor vehicle transactions and reporting thresholds.

Legal Sources and Quality Level

EU AMLR (EU) 2024/1624 – Articles 2, 3, 19–22, 67, 69, 73–74, 90 and Annex IV; EUR-Lex Summary; Swedish Financial Police; GDPR (EU) 2016/679. Version 1.0 · AI-assisted source review November 12, 2026. No independent legal review, official reporting channel verification for Article 74 after 2027, FIU reporting or authority approval has been carried out. Check current Swedish regulations and reporting forms before actual use.