The FIAU would like to bring to your attention that the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has launched a public consultation on the draft Implementing Technical Standards (ITS) under Article 69(3) of the Anti-Money Laundering Regulation (Regulation (EU) 2024/1624) (AMLR) concerning the format for reporting suspicions and providing transaction records.
Currently, suspicions are reported differently across EU Member States, which can complicate the exchange of information in cross-border situations. In view of this, through this draft ITS, AMLA is introducing a harmonised set of data points to create a consistent approach across Member States while still allowing some discretion to cover sector-specific needs. Reporting entities will need to fill in only the relevant data points, tailored to their type of activity and type of suspicion reported. This ensures more structured and comparable information, especially when reporting across borders.
The format and level of detail of transaction records also vary across Member States and among subject persons (obliged entities), creating challenges for cross-border financial analyses. Accordingly, this draft ITS also introduces standardised templates for the provision of transaction records by credit and financial institutions.
AMLA has scheduled an online public hearing on this draft ITS, which will take place on 9 September 2026 between 10:00 and 12:00 CET.
For further information on this draft ITS, reference should be made to the following link.
The FIAU encourages relevant subject persons (obliged entities) from both the financial and non-financial sectors to actively participate in this consultation process by reviewing the said consultation document and submitting their feedback through the following link by latest 20 September 2026, 23:59 CET.
It should be noted that feedback received through this consultation will be considered when preparing the draft ITS to be submitted to the Commission. When submitting feedback, AMLA encourages stakeholders to ensure their comments are clear and constructive. To be most effective, comments should: directly respond to the question posed, clearly indicate the relevant point, provide a well-supported rationale with evidence, and suggest alternative regulatory options for consideration.