The FIAU would like to bring to your attention that the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has published information on its public consultation process, including a currently open consultation on draft Implementing Technical Standards (ITS) under Art. 15(3) of the Anti-Money Laundering Authority Regulation (AMLAR).
AMLA conducts public consultations to gather feedback from stakeholders before finalising regulatory and policy measures. These consultations are open to a broad range of participants, including subject persons (obliged entities), and aim to ensure transparency, inclusiveness, and evidence-based policymaking. Public feedback helps to test the proportionality of proposed measures, assess their impact, and leverage external expertise at a stage when input can still shape policy choices. Responses will inform the finalisation of draft Regulatory and Implementing Technical Standards, Guidelines, Recommendations, Opinions, and Technical Advice. After each consultation closes, AMLA publishes a report summarising received feedback and explaining how it was taken into account. For further information on AMLA’s Public Consultations overview, reference should be made to the following link: https://www.amla.europa.eu/policy/public-consultations_en
Open Consultation on Art. 15(3) of the AMLAR:
AMLA has launched a public consultation on the draft ITS on cooperation within the AML/CFT supervisory system for the purposes of direct supervision under Article 15(3) of Regulation (EU) 2024/1620 of selected obliged entities that are credit institutions, financial institutions and groups of credit and financial institutions.
Article 15(3) of the AMLAR requires AMLA to issue draft ITS which set out:
- Conditions for assistance (Section 1 of the draft ITS)
- Process of periodic assessment (Section 2 of the draft ITS)
- Decision on the selection of obliged entities (Section 3 of the draft ITS)
- Transfer of supervisory tasks and powers (Section 4 of the draft ITS)
- Composition and functioning of the joint supervisory teams (‘JST’) (Section 5 of the draft ITS)
This draft ITS therefore plays an important role in ensuring consistency and continuity of AML/CFT supervision of obliged entities that transition between direct supervision by AMLA and their respective national AML/CFT supervisors. It complements provisions in Articles 12, 13, 15 and 16 of the AMLAR.
Feedback received through this consultation will be considered in the finalisation of the standards. 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. For further information reference should be made to the following link: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-its-under-art-153-amlar_en
The FIAU encourages relevant Subject persons (obliged entities) to actively participate in this consultation process by reviewing the said consultation document and submit their feedback through the following link by latest 27 January 2026, 23:59.