On 24 March 2026, AMLA held its first public hearings in relation to two draft Regulatory Technical Standards on business relationships and CDD (RTS) issued for consultation under the Anti-Money Laundering Regulation (AMLR). These RTS constitute an important next step toward the practical implementation of the new EU AML framework and provide an indication of how AML/CFT obligations will be applied in practice across Member States and sectors.

Recap of new EU anti‑money laundering legislative package

In 2024, the European Union adopted an extensive new anti‑money laundering legislative package aimed at strengthening and harmonising AML/CFT requirements across the EU. A central element of the package is the AMLR (Regulation (EU) 2024/1624), which introduces a directly applicable “single rulebook” replacing large parts of national AML laws. In parallel, the sixth Anti‑Money Laundering Directive (Directive (EU) 2024/1640, AMLD6) sets out rules on supervision, enforcement and national institutional arrangements, which Member States must transpose into national law. The package also establishes a new EU‑level authority, AMLA, responsible for direct and indirect supervision, coordination of national authorities and the development of regulatory technical standards. The AMLR and AMLD6 entered into force on 10 July 2024 and will largely become applicable as of 10 July 2027, significantly reforming the EU AML framework. For a more detailed overview of the relevant changes, reference is made to our previous article.  

AMLA’s role and level 2 legislation

On 24 March 2026, the first public hearings took place by AMLA. During the public hearings, AMLA emphasised that stakeholder engagement is a core element of its mandate. These hearings form part of AMLA’s broader objective to develop a strong, effective and uniform AML/CFT framework throughout the EU, in close interaction with obliged entities in both the financial and non‑financial sectors.

AMLA reiterated its key tasks, which include:

  • AML/CFT supervision, including direct supervision of a limited number of high‑impact financial institutions and indirect supervision of the remaining institutions;
  • oversight and coordination of supervisory authorities in the non‑financial sector;
  • coordination and support of EU Financial Intelligence Units (FIUs); and
  • acting as an EU‑level regulator through the development of technical standards and guidelines addressed at obliged entities, supervisors and FIUs.

The RTS form part of the level 2 legislative framework under the AMLR. While level 2 measures cannot amend the AMLR itself, they are legally binding and intended to supplement and clarify level 1 legislation in order to ensure consistent practices and uniform application of EU AML rules.

Two draft RTS opened for consultation

AMLA has made two draft RTS available for public consultation:

  1. Draft RTS under Article 19(9) AMLR on the criteria for identifying business relationships, occasional transactions and linked transactions; and
  2. Draft RTS under Article 28(1) AMLR specifying customer due diligence (CDD) requirements.

Both draft RTS have a broad scope, applying to obliged entities in both the financial and non‑financial sector.

The draft RTS under Article 19(9) AMLR clarifies how interactions should be qualified as business relationships, occasional transactions or linked transactions. This distinction is crucial because it determines whether CDD must be applied and, if so, when. While the AMLR already defines business relationships and linked transactions, the RTS aim to reduce divergent practices across Member States, thereby achieving harmonisation and address practical application challenges. For example, AMLA proposes a negative definition of occasional transaction: everything that is not a business relationship is an occasional transaction. During the hearing various questions were raised and discussed by the participants.

The draft RTS under Article 28 AMLR further specifies CDD requirements, including the information to be collected for simplified, standard and enhanced due diligence, the types of simplified measures, risk factors related to electronic money, acceptable verification sources and requirements for electronic identification. In developing the RTS, AMLA focused on harmonisation across the EU, preservation of the risk‑based approach, proportionality, technological neutrality and continuity with existing EU guidance. The RTS aim to support consistent and practical application of CDD obligations across sectors. In practice more information will be required than under the current approach, primarily because the information must be more specific, the underlying rationale must be more clearly documented and it is no longer sufficient to rely on general descriptions.

Again, various practical aspects were discussed during the hearing. One of the developments also discussed was that AMLA is currently working on a draft RTS specifically addressing information sharing within groups, which will provide further clarity on how CDD information may be reused and shared among group entities. It was furthermore helpfully reconfirmed that for existing customer files, the expectation is that they must be updated to reflect the new requirements under AMLR, while new customers will need to be onboarded in line with the updated legislation after July 2027. AMLA indicated that there is no expectation that all existing customers must be fully updated by July 2027. Article 26 AMLR establishes that updates to existing customer files should follow a risk‑based approach in accordance with applicable policies. This means that institutions should prioritise high‑risk customers first, and then update all others within the applicable timeframe.

Consultation timeline and next steps

The public consultation on both draft RTS will remain open until 8 May 2026. AMLA plans to submit the revised draft RTS to the European Commission in Q3 2026. The final RTS will apply from 10 July 2027 onwards, in line with the broader AML legislative package.

Looking ahead

The publication of these draft RTS marks an important milestone in the transition to the new EU AML framework. The AMLR and AMLD6 will significantly change the current AML landscape and more details about the practical implementation of the new EU AML framework have now become known. With the AMLR’s entry into force approaching, obliged entities are encouraged to assess the impact of the new framework, including the proposed RTS, on their governance structures, policies, procedures and systems.

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