AMLR blog
Articles on the EU Anti-Money Laundering Regulation (AMLR), AMLD6, AMLA and the RTS, Guidelines and ITS that shape them: what changes, what it means for obliged entities and what to do now.
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- · AMLA · OLAF · joint analyses
AMLA and OLAF sign a working arrangement: what it means for your reports
AMLA and OLAF signed a working arrangement on 21 October 2026 under Article 94 AMLAR. What it covers, how it links to joint analyses, and what obliged entities should do.
- · AMLA · MiCA · crypto-asset service providers
AMLA's MiCA review response: five crypto gaps it wants closed
AMLA has told the Commission where MiCA leaves ML/TF risk uncovered: staking and lending, DeFi control, unauthorised stablecoins, ART issuers and CASP passporting.
- · AMLA · RTS · central database
AMLA consults on the central AML/CFT database RTS: what supervisors will share
AMLA's draft RTS under Article 11(6) AMLAR defines what supervisors report on obliged entities to an EU-wide database. Public hearing on 3 November 2026.
- · RTS · customer due diligence · occasional transactions
AMLA publishes final draft RTS on CDD, occasional transactions and groups
AMLA has sent three final draft RTS on customer due diligence, business relationships and group-wide arrangements to the Commission. What changed and what to do.
- · AMLD6 · central contact points · payment service providers
Central contact points: AMLA's RTS for PSPs, EMIs and CASPs takes shape
AMLA has surveyed EMIs and PSPs on central contact points ahead of its RTS under Article 41 AMLD6. What the current rules say, what changes, and how to prepare.
- · AMLA · supervisory fee · direct supervision
AMLA's annual supervisory fee: which institutions pay, selected or not
AMLA will charge an annual fee to the institutions it selects and to every credit or financial institution active in six or more Member States. Who pays, how it is calculated and what is still open.
- · AMLA · non-financial sector · supervision
What AMLA means for notaries, lawyers, accountants and estate agents
AMLA will not supervise notaries, lawyers, accountants or estate agents and charges them no fee. It still shapes their work, through the rules it writes and the peer reviews of their supervisors.
- · AMLA · RTS · AMLD6
Five days left: AMLA's risk-rating RTS for the non-financial sector
AMLA's draft RTS on the risk profile of non-financial obliged entities closes on 27 September 2026. What it proposes, why it matters and how to respond.
- · AMLD6 · RTS · sanctions
The RTS on sanctions is final: how supervisors will grade and price breaches
AMLA's final draft RTS under Article 53(10) AMLD6 gives supervisors a four-step method to grade breaches and set fines. What it means for obliged entities.
- · AMLAR · guidelines · comply-or-explain
Comply-or-explain: how AMLA guidelines bind supervisors and obliged entities
AMLA guidelines are not law, but they are not optional either. What Article 54 AMLAR means for supervisors and firms, and how to handle the pipeline of guidelines still to come.
- · AMLR · 10 July 2027 · customer due diligence
What changes on 10 July 2027: the AMLR in ten obligations
From 10 July 2027 the EU Anti-Money Laundering Regulation applies directly. Ten obligations that change the day-to-day work of obliged entities, with the articles and what to do now.
- · status · AMLA · RTS
Six weeks after the first tranche: where AMLA's standards stand
A status check in early September 2026: seven final reports, seven consultations closed and being finalised, three open, a dozen guidelines not yet drafted. What is settled, what is not, and what obliged entities should do this quarter.
- · ITS · suspicious transaction report · FIU
The ITS on the suspicious transaction report: prepare your data now
AMLA consulted (2 July to 20 September 2026) on the implementing technical standard that fixes the template for reporting suspicious transactions to FIUs. What the template will ask for and how to get your data ready.
- · Guidelines · business-wide risk assessment · SIRA
The Guidelines on the business-wide risk assessment: what the consultation asks of you
AMLA consulted on Guidelines for the business-wide risk assessment under Article 10 AMLR until 15 July 2026 and is finalising them. The structure they expect, the link to the supervisory methodology and what changes for institutions with a SIRA.
- · ongoing monitoring · periodic review · transaction monitoring
Ongoing monitoring under the AMLR: review frequencies and event-driven reviews
Article 26 AMLR makes ongoing monitoring a duty with fixed elements, and AMLA consulted on Guidelines for it until 3 September 2026. How periodic reviews, event-driven reviews and transaction monitoring fit together.
- · AMLA · direct supervision · selection
Who will AMLA supervise directly in 2028? The selection methodology explained
The RTS on the selection of obliged entities for direct AMLA supervision, submitted to the Commission, sets the method: cross-border activity and a high residual risk. What the first selection round means for candidate institutions.
- · governance · compliance manager · compliance officer
The compliance manager at board level: who, what and how to evidence it
Article 11 AMLR requires a compliance manager in the management body next to the compliance officer. What the role involves, how it differs from the compliance officer and what supervisors will ask to see.
- · beneficial ownership · UBO · Article 51
The 25% beneficial ownership threshold and control through other means
Articles 51 to 56 AMLR replace national thresholds with one rule: 25% ownership, plus control through other means, traced through multi-layered structures. What to collect, verify and record from 10 July 2027.
- · outsourcing · reliance · Article 18
Outsourcing and reliance under the AMLR: what may leave the building and what must stay
Article 18 sets hard limits on outsourcing AML tasks; Articles 48 and 49 govern reliance on other obliged entities. Which tasks stay in-house, what contracts must contain and what AMLA's planned Guidelines will add.
- · PEP · enhanced due diligence · Article 42
Politically exposed persons under the AMLR: the twelve-month rule and the lists of prominent public functions
Articles 42 to 46 AMLR harmonise who counts as a PEP, require Member States to publish lists of prominent public functions and keep measures in place for at least twelve months after office. What changes for screening and reviews.
- · sanctions · screening · Article 27
Sanctions screening becomes a customer due diligence measure (Article 27 AMLR)
The AMLR makes verifying whether a customer or beneficial owner is subject to EU targeted financial sanctions part of due diligence. What it means for onboarding, list updates and sectors new to screening.
- · enhanced due diligence · high-net-worth · Article 34
Enhanced due diligence for high-net-worth customers: the €50 million and €5 million tests
Article 34 AMLR requires enhanced measures for customers with wealth of at least €50 million or assets of at least €5 million handled by the institution. Source of wealth, senior approval and what private banks must change.
- · crypto-assets · CASP · self-hosted addresses
Crypto under the AMLR: correspondent relationships with CASPs and self-hosted addresses
Articles 37 and 38 AMLR set enhanced measures for relationships with crypto-asset service providers and for transactions with self-hosted addresses. What CASPs and the banks that serve them must do.
- · group · third countries · Article 16
Group-wide policies and third-country branches: managing conflicting laws under the AMLR
Articles 16 and 17 AMLR require parent undertakings to implement group-wide policies, including information sharing, and to manage branches in third countries whose law is less strict or forbids the group policy.
- · simplified due diligence · Article 33 · risk-based approach
Simplified due diligence under the AMLR: when low risk really is low
Article 33 AMLR allows simplified measures only after a documented low-risk assessment and never where suspicion exists. What simplified means, which factors count and what the CDD RTS specifies.
- · RTS · AMLA · European Commission
The first tranche of RTS is with the Commission: what happens next
10 July 2026 was the statutory deadline for the first tranche of technical standards: AMLA delivered some of them and rescheduled the rest. How adoption, scrutiny and publication work, and what obliged entities can already do.
- · programme · planning · 10 July 2027
One year to go: a twelve-month plan to 10 July 2027
With twelve months left before the AMLR applies, a quarter-by-quarter plan for an obliged entity: gap analysis, design, build, test, and the evidence supervisors will want to see on day one.
- · record keeping · data protection · GDPR
Record retention under the AMLR: five years, then deletion, and the data-protection balance
The AMLR sets a five-year retention period for customer due diligence and transaction records and requires deletion afterwards. How to reconcile it with GDPR, litigation holds and the reporting template.
- · Netherlands · Wwft · AMLD6
The Dutch implementation act for the AML package: what stays national
The Netherlands is consulting on the Implementatiewet AML-pakket that implements AMLD6 and adjusts the Wwft. What remains national next to the directly applicable AMLR: supervisors, FIU-Netherlands, registers, sanctions and the cash limit.
- · cash limit · traders in goods · dealers
The €10,000 cash limit and what it means for traders in goods and services
The AMLR caps cash payments at €10,000 for traders in goods and services across the EU, with Member States free to set a lower limit. Who is affected, what must be refused and what obliged entities must record.