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.
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Article 34 of the AMLR introduces a category that did not exist in the directives: customers, or beneficial owners of customers, with a total wealth of at least €50 million, or for whom the obliged entity manages assets of at least €5 million, bring enhanced due diligence with them. AMLA's draft Guidelines on enhanced due diligence for high-net-worth individuals and large private wealth, in final draft, describe the measures.
The two thresholds
The wealth test looks at the person: total wealth of €50 million or more, in financial assets, real estate, business interests or otherwise, excluding the main residence. The asset test looks at the relationship: assets of €5 million or more managed, held or transacted through the institution. Either triggers the measures.
The measures
- Establish the source of wealth and the source of funds with evidence, not a self-declaration alone.
- Obtain senior management approval to start or continue the relationship.
- Apply closer monitoring, with review frequencies at the higher-risk end.
- Where the customer is also a PEP or linked to a high-risk third country, the measures cumulate.
What changes for private banks and wealth managers
Most private banks already collect source-of-wealth narratives. The AMLR turns them into a documented, evidenced assessment with a threshold that applies regardless of the institution's own risk classification. Wealth managers with a modest AML programme, family offices that qualify as obliged entities, and trust offices serving wealthy families are affected most.
Practical questions
How to establish total wealth when the customer holds assets elsewhere; how to treat a beneficial owner of a corporate customer whose personal wealth exceeds the threshold; and how to review the classification when values change. The Guidelines expect a reasonable effort based on available information and a periodic recheck, not certainty.
What to do now
- Tag the customers who meet either test; private-banking units usually know them but rarely record the classification.
- Define what "evidenced" source of wealth means for your institution and update the onboarding checklist.
- Set the senior-approval workflow and the review frequency for this category.
The dashboard tracks the HNWI Guidelines under Enhanced Due Diligence.