AMLA consults on draft RTS on customer due diligence and harmonized supervision

Established with Regulation (EU) 2024/1620, AMLA is the new European authority, based in Frankfurt, responsible for the effective and consistent functioning of the AML/CFT European supervisory system and the effective and consistent cooperation between financial intelligence units.

Among its various mandates, AMLA is delegated by Regulation (EU) 2024/1624 (“AMLR”) and Directive (EU) 2024/1640 (“AMLD6”) to develop harmonized rules for the prevention of money laundering and terrorist financing, including by drafting RTS.

Within this mandate, AMLA issued on 9 February 2026 three consultations on three draft RTS, respectively on:

1. Customer due diligence, including on requirements and information to be collected for standard, simplified, and enhanced customer due diligence pursuant to Article 28(1) of the AMLR. The draft RTS include rules on, inter alia, risk factors that supervisors must consider when determining the extent to which certain electronic money instruments may be exempted from some customer due diligence measures and attributes which electronic identification means must feature to fulfill the requirements of the AMLR in the case of standard, simplified, and enhanced due diligence. The provisions of this draft RTS will have a significant impact to all obliged entities and the internal measures they have put in place to comply with the harmonised customer due diligence requirements;
2. Criteria for identifying business relationships, occasional transactions and linked transactions as well as high-risk obliged entities, sectors or transactions to which a lower threshold for customer due diligence measures should apply pursuant to Article 19(9) of the AMLR; and
3. For the non-financial sector indicators to classify the level of seriousness of breaches of AML/CFT obligations, criteria to be taken into account when setting the level of pecuniary sanctions or applying administrative measures, and methodology for the imposition of periodic penalty payments (including their frequency) pursuant to Article 53(10) of the AMLD6. The draft RTS aim to guarantee that the same AML/CFT breach is assessed in the same way by all supervisors in all member States, in line with the AMLA mandate to ensure effective, consistent, and harmonized functioning of the AML/CFT supervisory system.

The European Banking Authority (EBA) previously consulted the financial sector on the proposed draft RTS under (i) and (iii) above and AMLA is now conducting its own public consultation in order to fully capture the views of the financial and non-financial sector. Indeed, according to the new European AML/CFT framework, new and more non-financial entities will be subject to AML/CFT requirements (such as football agents and clubs, as mentioned in our previous newsflash), and AMLA particularly welcomes their input, given the limited participation in the EBA consultations.

Next steps

The consultations on customer due diligence (available here) and on criteria for identifying business relationships, occasional and linked transactions and lower thresholds (available here) will be open until 8 May 2026, while the consultation of the non-financial sector on pecuniary sanctions and harmonized supervision (available here) will be open until 9 March 2026. Interested parties may respond electronically via AMLA's website in all official EU languages. AMLA scheduled an online public hearing on the draft RTS on customer due diligence and business relationships for 24 March 2026.

Authored by Jeffrey Greenbaum, Elisabetta Zeppieri, Andrea Manta and Giulia Marinai.