Six weeks after the first tranche: where AMLA's standards stand
A status check in early September 2026: four RTS with the Commission, three consultations open, a dozen Guidelines in final draft. What is settled, what is not, and what obliged entities should do this quarter.
Ten months before the AMLR applies, the regulatory picture is clearer than it was in spring, but not finished. This is where the instruments tracked on the AMLR Monitor dashboard stand at the start of September 2026, and what it means for the coming quarter.
Settled: the Level-1 texts
The AMLR, AMLD6 and the AMLA Regulation are published and in force; only their application dates lie ahead. Nothing in the Level-2 process can change the obligations they contain: the 25% beneficial ownership threshold, the compliance manager, the cash limit, suspicion-based reporting, the five-year retention period.
With the Commission: four RTS
The RTS on customer due diligence, on the risk-assessment methodology, on the selection of obliged entities for direct supervision and on pecuniary sanctions were submitted by the 10 July deadline. Adoption as delegated regulations, scrutiny by Parliament and Council and publication in the Official Journal follow. Their substance is known; their exact legal wording is not yet final.
In consultation: three instruments
The ITS on the suspicious transaction report template, the Guidelines on the business-wide risk assessment and the Guidelines on ongoing monitoring are open for comment. These are the last chance to influence texts that decide the data model of the customer file and the shape of monitoring.
Final draft, not yet published: a dozen Guidelines
Internal policies and controls, group-wide policies, outsourcing, reliance and third-party information, risk factors, customer risk classification, PEPs, high-risk third countries, enhanced due diligence for crypto and for high-net-worth customers, and the reporting of suspicious transactions. These texts are stable enough to design against.
What this quarter should deliver
- A gap analysis on the compliance framework with owners per block.
- Consultation responses on the STR template and the risk-assessment Guidelines where they touch your sector.
- The customer data model designed against the CDD RTS and the STR template together.
- The governance decisions: compliance manager, programme owner, board cadence.
What to watch
Commission adoption decisions on the first tranche, the closing dates of the open consultations, and the Dutch implementation act. The dashboard updates when a status changes, and the daily source check lists new publications the day they appear.