SEK 10,000 Cash Limit: Riksbank Pushes Below the EU AML Ceiling

On 29 October 2026 the Riksbank published its consultation response to the Ministry of Finance memorandum EU:s penningtvättspaket (Fi2026/01654), and its main request is a SEK 10,000 cash limit for retail transactions. The memorandum proposes leaving the option in Article 80(2) of Regulation (EU) 2024/1624 (the AMLR) unused, so the EU ceiling of EUR 10,000 would also be Sweden’s. The Riksbank opposes that.

The figure reaches beyond retail. The memorandum links the cash ban limit to which goods traders stay inside the Swedish AML perimeter, and Article 80 requires cash payments and deposits above the limit at bank, e-money and payment service provider premises to be reported to the financial intelligence unit (FIU). Consultation responses were due by 30 October 2026, and the memorandum proposes that most Swedish changes enter into force on 10 July 2027, when the AMLR starts to apply.

Related reading: The EU AML Package: The Countdown to 10 July 2027

Where the SEK 10,000 cash limit proposal stands

The Riksbank recommended a maximum limit for cash purchases, without a figure, in its Payments Report 2025, and its Payments Report 2026 recommended SEK 10,000 to the Government and Riksdag. The consultation response, dated 21 October 2026 and decided by the Executive Board, restates it against the memorandum’s text.

• 12 March 2026: Payments Report 2026 recommends a SEK 10,000 limit for retail cash purchases.
• 6 July 2026: the Ministry of Finance publishes the memorandum for consultation.
• 29 October 2026: the Riksbank publishes its response.
• 30 October 2026: consultation deadline.
• 10 July 2027: the AMLR applies (Article 90 sets 10 July 2029 for two categories of obliged entities); proposed main Swedish entry-into-force date.

The Riksbank’s evidence rests on a proxy it names: card purchases above SEK 10,000 are well under 1 percent of retail purchases, and card data is the closest equivalent to cash it has. The memorandum notes the same gap: surveys show five percent of respondents used cash at their latest shop purchase (close to 40 percent in 2010) but say nothing about payment size. Both cite Denmark, which prohibits cash payments of DKK 15,000 or more, a little over SEK 20,000 by the Riksbank’s figure.

What Article 80 of the AMLR sets, and the room it leaves Sweden

Article 80(1) allows persons trading in goods or providing services to accept or make a cash payment only up to EUR 10,000 or the equivalent in national or foreign currency, in one operation or in several that appear to be linked. Under Article 80(2) a Member State may adopt a lower limit after consulting the European Central Bank under Council Decision 98/415/EC, notifying the Commission within three months of introducing it.

Article 80(3) preserves national limits already below EUR 10,000. That route is closed to Sweden: the memorandum records that Swedish law has no existing cash ban limit, so SEK 10,000 would be a new Article 80(2) measure, ECB consultation included.

The limit binds businesses whether or not they run an AML programme. Recital 18 explains that it replaces the Directive (EU) 2015/849 approach of making traders in goods obliged entities above EUR 10,000 in cash; only traders in precious metals, precious stones, other high-value goods and cultural goods stay subject to AML obligations. A retailer outside the obliged-entity list is still bound by Article 80.

Payments between natural persons not acting in a professional capacity fall outside the limit (Article 80(4)(a)), as do payments or deposits at the premises of credit institutions, e-money issuers and payment service providers (Article 80(4)(b)). Article 80(7) lets a Member State suspend the limit temporarily where non-cash means of payment become unavailable nationally by reason of force majeure.

Cash traders: EUR 5,000 today, SEK 55,000 in the memorandum

Under Directive (EU) 2015/849, persons trading in goods are obliged entities where cash payments of EUR 10,000 or more are made or received. According to the memorandum, Swedish law lowers that to EUR 5,000 in Chapter 1, Section 2, first paragraph, point 16 of the Money Laundering Act (2017:630).

The AMLR drops the category, and the memorandum proposes keeping it as a national choice. Companies trading goods for cash would stay subject to the AML rules where transactions involving SEK 55,000 or more in cash, paid out or received, can be expected; the memorandum expresses the threshold in kronor instead of euro, and the Riksbank response describes SEK 55,000 as corresponding to the current limit. That means continued risk assessment, customer due diligence and reporting of suspicious transactions to Finanspolisen. Article 3 of Directive (EU) 2024/1640 (AMLD6) is the procedure for national add-ons of this kind, and the memorandum notes that goods traders taking or paying out large cash amounts must register in the AML register kept by the Swedish Companies Registration Office (Bolagsverket).

The two thresholds interact. The memorandum argues they have to relate to each other, and that a much larger cut in the ban would leave no basis for keeping cash traders as obliged entities. The arithmetic explains why, as I read it: with a ban at SEK 10,000, a goods trader could no longer lawfully take SEK 55,000 in cash within Article 80’s scope, so the SEK 55,000 trigger would describe transactions the ban already prohibits. The Riksbank rejects the memorandum’s assessment and notes, as the memorandum itself records, that the EU judged the cash-trader regime ineffective and left it out of the AMLR; the Riksbank proposes no replacement threshold for cash traders.

Cash at bank, PSP and e-money counters

Article 80(4)(b) keeps counter business at credit institutions, e-money issuers and payment service providers outside the limit, and requires payments and deposits above the limit to be reported to the FIU within the deadlines the FIU sets. In Sweden the FIU is the Police Authority (Polismyndigheten).

The memorandum splits the mechanics between the Act and secondary rules: a new Money Laundering Act provision pointing to the AMLR duty, a power for the Government or a designated authority to set the reporting deadline, and Police Authority regulations on how reports are made. It notes the AMLR does not specify the report’s content and assumes details such as the depositor and the amount.

A SEK 10,000 limit would raise two questions the Riksbank response does not address. The first is the reporting trigger. On my reading, Article 80(4) ties both the counter carve-out and the FIU report to the paragraph 1 limit of EUR 10,000. Under the memorandum’s position the figures coincide; under the Riksbank’s they would diverge, and the response does not say which one a bank would report against.

The second is identification. Article 19(4) of the AMLR requires obliged entities to identify and verify the customer for occasional cash transactions of EUR 3,000 or more, and switches that floor off in Member States with an Article 80(2) or (3) limit of EUR 3,000 or less, except for payments and deposits at the premises covered by Article 80(4)(b). Taking SEK 55,000 as equivalent to the current EUR 5,000 limit, as the Riksbank response does, SEK 10,000 is roughly EUR 900 by my calculation. On my reading, a SEK 10,000 limit would switch off the EUR 3,000 floor for other obliged entities, while banks, e-money issuers and payment service providers would keep it for cash at their premises.

These counter flows sit next to the obligations in our guide to Sweden periodic AML reporting to Finansinspektionen and our note on Finansinspektionen’s 2026 AML, CFT and sanctions priorities. My working assumption for anyone scoping the counter-reporting build: keep the threshold configurable until the legislation fixes it.

Supervision and sanctions in the memorandum’s draft

The Government would designate the supervisor in rules below statute level. The memorandum’s assessment is that the County Administrative Boards of Skåne, Stockholm and Västra Götaland should take the task, mainly because they already supervise cash traders for AML purposes. It weighed the Swedish Tax Agency and set it aside, partly because cash-register rules cover a different set of businesses.

Supervisors would get information orders backed by conditional fines (vite) and on-site inspections limited to activities where the ban applies, without access to documents covered by lawyers’ professional secrecy. The memorandum opts for administrative sanction fees over criminal liability. It notes that Denmark and Malta criminalise breaches of their cash bans, and the Danish penalty range includes imprisonment.

The proposed fee for a sole trader is SEK 10,000 to 30,000. For legal persons it runs in four turnover bands, from SEK 20,000 to 60,000 where turnover is below SEK 1 million up to SEK 80,000 to 240,000 where annual turnover exceeds SEK 50 million. Several breaches attract one joint fee, capped at twice the band maximum. The excess over the limit is meant to weigh most, and no fee is proposed on board members or managing directors.

Article 80(5) refers to persons “suspected of a breach”. The memorandum reads that as requiring the same standard of proof as other AML supervision before a fee is imposed, so suspicion alone would fall short. The ban carries no intent or negligence requirement, which is why the memorandum wants the law to state expressly that the fee can be reduced or waived.

Frequently Asked Questions

Would a SEK 10,000 cash ban change the cash-acceptance duty for grocery stores and pharmacies?

The two rules would apply side by side. Act (2026:769), in force since 1 July 2026, requires grocery stores and pharmacies to accept cash at staffed tills in physical outlets, for payments of up to 0.1 price base amount (SEK 5,920 for 2026) and 25 coins, subject to security, handling-cost and individual-sale exceptions. That is a floor on acceptance; the cash ban is a ceiling on payment. The Riksbank argues a SEK 10,000 ban sits well in line with it.

Is a report of a cash deposit above the limit a suspicious transaction report?

Recital 162 of the AMLR says such payments or deposits should not by default be treated as an indicator of suspicion, and that these threshold-based disclosures are distinct from suspicious transaction reports and do not replace them or enhanced due diligence in higher-risk cases. It also anticipates FIU deadlines that could include periodic aggregated submission; the memorandum leaves Swedish timing to regulations.

Can one cash purchase be split into several payments to stay under the limit?

Article 80(1) applies the limit to several operations which appear to be linked, so splitting a purchase does not by itself take it outside the limit. AMLA’s linked-transaction criteria, covered in our article on the AMLA final RTS on CDD data and linked transactions, are set out in draft form under the customer due diligence mandate in Article 19(9)(d) and are not yet in force; Article 80(1) itself carries the linked-operations wording for the cash limit. The memorandum’s cash ban chapter sets no Swedish linkage criteria for Article 80.

Related Articles

• The EU AML Package: The Countdown to 10 July 2027: how the AMLR, AMLD6 and AMLA fit together from 10 July 2027.
• Sweden Periodic AML Reporting: Preparing for FI’s Updates: Finansinspektionen’s periodic AML reporting and who files.
• Finansinspektionen 2026 AML, CFT and Sanctions Priorities: FI’s 2026 priorities for Swedish banks, payment institutions and CASPs.

Key Takeaways

• Watch one figure in the Government’s proposal: EUR 10,000 (memorandum) or SEK 10,000 (Riksbank).
• Bank, e-money and payment service provider counter teams: the Swedish reporting deadline and format would come from regulations below the Act.
• Goods traders expecting cash of SEK 55,000 or more stay obliged entities under the memorandum; a SEK 10,000 ban would reopen that threshold.
• Breaches would be administrative only: a single-breach maximum of SEK 240,000 for the largest legal persons, and no fee on management.

Sources and References

• Sveriges Riksbank, “Introduce a cash limit of SEK 10,000” (29 October 2026): riksbank.se
• Sveriges Riksbank, Remissvar angående promemorian EU:s penningtvättspaket (21 October 2026, Swedish): PDF
• Sveriges Riksbank, Payments Report 2025, recommendation on a maximum amount for cash purchases (10 March 2025): riksbank.se
• Sveriges Riksbank, Payments Report 2026, “A limit of SEK 10,000 should be introduced for cash purchases in the retail sector” (12 March 2026): riksbank.se
• Regeringskansliet, Promemoria EU:s penningtvättspaket (Fi2026/01654, 6 July 2026), sections 5.3 and 13: regeringen.se and PDF
• Regeringskansliet, Remiss av promemorian EU:s penningtvättspaket (deadline 30 October 2026): regeringen.se
• Lag (2026:769) om skyldighet för livsmedelsbutiker och apotek att ta emot kontant betalning (in force 1 July 2026, Swedish): riksdagen.se
• Regulation (EU) 2024/1624 (AMLR), recitals 18 and 162, Articles 19, 80 and 90: EUR-Lex
• Directive (EU) 2015/849, Article 2(1), point (3)(e) (repealed with effect from 10 July 2027 by Article 77 of Directive (EU) 2024/1640): EUR-Lex
• Directive (EU) 2024/1640 (AMLD6), Articles 3 and 77: EUR-Lex

EUR 10,000 or SEK 10,000: the figure the legislation has to fix

If the Government keeps EUR 10,000, the counter-reporting trigger and the SEK 55,000 cash-trader threshold work as the memorandum drafted them. If it adopts SEK 10,000, Article 80(2) requires ECB consultation and notification to the Commission, and on my reading the cash-trader threshold, the counter-reporting figure and the EUR 3,000 identification floor would all need revisiting. The limit in the Government’s legislative proposal, with 10 July 2027 as the memorandum’s target date, is the input to confirm before the over-the-counter reporting flow is built.

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