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 open public consultations on three draft Regulatory Technical Standards (RTS) as follows:
- Draft RTS on customer due diligence (Article 28(1) AMLR)
AMLA has launched a public consultation on the draft RTS setting out the requirements and information to be collected for standard customer due diligence (CDD), simplified due diligence (SDD) and enhanced due diligence (EDD) purposes, under Article 28 (1) of the Anti-Money Laundering Regulation (Regulation (EU) 2024/1624) (AMLR). The aim is to ensure that CDD measures are applied consistently across the EU. It should be noted that the European Banking Authority (EBA) previously consulted on a version of this draft RTS and gathered feedback from all stakeholders. In 2025, AMLA took over this work, building on the EBA’s efforts to ensure legal clarity, proportionality, a risk-based approach, and applicability to all obliged entities. This public consultation aims to further refine the RTS, with a special focus on incorporating feedback from the non-financial sector into the final draft given their limited participation in the previous EBA consultations.
AMLA has also scheduled an online public hearing on this draft RTS on the 24th of March 2026. Additional information on the public hearing will be made available by AMLA in due course.
For further information on this draft RTS, reference should be made to the following link.
The FIAU encourages relevant subject persons (obliged entities) to actively participate in this consultation process by reviewing the said consultation document and submitting their feedback through the following link by latest 8 May 2026, 23:59.
- Draft RTS on criteria for identifying business relationships, occasional and linked transactions and lower thresholds (Article 19(9) AMLR)
AMLA has launched a public consultation on the draft RTS specifying criteria for identifying business relationships, occasional transactions and linked transactions, developed under Article 19 (9) of the AMLR.
Article 19(9) of the AMLR seeks to ensure the consistent and proper identification of business relationships, occasional transactions, and linked transactions across the Union, thereby safeguarding the effective application of the AML/CFT framework and preventing the circumvention of thresholds for occasional transactions. Secondly, it aims to ensure that heightened money laundering and terrorist financing (ML/TF) risks associated with occasional transactions are adequately mitigated. The draft RTS adopts a proportionate, risk-based approach and reflects a commitment to simplification, as AMLA has not identified additional higher risks at this stage that would justify the introduction of lower thresholds.
The criteria in this draft RTS applies to all obliged entities across both the financial and non-financial sectors, therefore AMLA welcomes responses from all stakeholders.
AMLA has also scheduled an online public hearing on this draft RTS on the 24th of March 2026. Additional information on the public hearing will be made available by AMLA in due course.
For further information reference should be made to the following link.
The FIAU encourages relevant subject persons (obliged entities) to actively participate in this consultation process by reviewing the said consultation document and submitting their feedback through the following link by latest 8 May 2026, 23:59.
- Draft RTS on pecuniary sanctions, administrative measures and periodic penalty payments (Article 53(10) AMLD6)
AMLA has launched a public consultation on the draft RTS under Article 53 (10) of Directive (EU) 2024/1640 (AMLD6), setting out indicators for classifying the level of gravity of breaches, criteria to be taken into account when setting the level of pecuniary sanctions or applying administrative measures, and a methodology for the imposition of periodic penalty payments. It seeks to ensure that the same breach is assessed in the same way by all supervisors in all Member States, and that the resulting enforcement measures are proportionate, effective and dissuasive.
The EBA previously consulted on a version of this draft RTS and invited feedback from all stakeholders. This public consultation exercise aims to ensure that the view of the non-financial sector is captured and, where necessary, reflected in the final draft. AMLA particularly welcomes input from the non-financial sector, given their limited participation in the EBA consultations held in early 2025, which primarily targeted the financial sector.
For further information reference should be made to the following link.
The FIAU encourages relevant subject persons (obliged entities) to actively participate in this consultation process by reviewing the said consultation document and submitting their feedback through the following link by latest 9 March 2026, 23:59.
It should be noted that feedback received through these three consultations will be considered when preparing the draft RTS 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.
