The Financial Intelligence Analysis Unit (FIAU) would like to bring to your attention the publication by the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) of a final report containing two draft Regulatory Technical Standards (RTSs) concerning:
- The assessment of the inherent and residual risk profile of obliged entities, under Article 40(2) of Directive (EU) 2024/1640 (the Anti-Money Laundering Directive – AMLD); and
- The risk assessment methodology for the purpose of selection of credit institutions, financial institutions, and groups of credit and financial institutions for direct supervision by AMLA, under Article 12(7) of Regulation (EU) 2024/1620 (the Anti-Money Laundering Authority Regulation – AMLAR).
In line with the procedure set out in Article 49 of Regulation (EU) 2024/1620 (AMLAR), the draft RTSs were initially developed by the European Banking Authority (EBA) following a call for advice and were subject to a public consultation process. Following the handover of these draft RTSs to AMLA and the assessment of the feedback received, AMLA will submit the final reports to the European Commission for adoption. At the same time, the draft RTSs will be transmitted for information to the European Parliament and the Council. Once adopted, the RTSs will be published in the Official Journal of the European Union.
1. Draft Regulatory Technical Standards on the assessment of the inherent and residual risk profile of obliged entities (Article 40(2) AMLD)
Article 40(2) of the AMLD mandates AMLA to develop draft RTSs establishing a common methodology to be used by supervisors when assessing the level of money laundering and terrorist financing (ML/TF) risk to which obliged entities are exposed. The methodology sets out how supervisors are to classify inherent and residual risk profiles, as well as the frequency with which such risk profiles must be reviewed. The draft RTS applies to supervisors that are responsible for the AML/CFT supervision of financial sector obliged entities. It reflects the feedback received during a three-month public consultation on a version of the draft RTS, which took place between March and June 2025.
This draft RTS introduces a fully harmonised, risk-based methodology. It establishes a core set of datapoints applicable to all obliged entities, complemented by sector-specific datapoints. The frequency of supervisory reviews is calibrated to reflect the nature, size, and complexity of obliged entities. Once implemented, the methodology will support supervisors in shaping supervisory strategies and inspection plans, while fostering a shared understanding of how different risk factors contribute to an entity’s overall ML/TF risk exposure. A harmonised approach is expected to enhance operational efficiency and ensure more reliable and comparable supervisory outcomes across the EU.
The full text of this draft RTS may be accessed on AMLA’s website through the following link
2. Draft Regulatory Technical Standards on the risk assessment for the purpose of selection of credit institutions, financial institutions and groups of credit and financial institutions for direct supervision under Article 12(7) of Regulation (EU) 2024/1620
Article 12(7) of Regulation (EU) 2024/1620 requires AMLA to specify, through draft RTSs, key elements of the methodology it will apply when selecting credit institutions, financial institutions, and groups of credit and financial institutions that it will supervise directly.
As an initial step, AMLA will identify obliged entities that are eligible for direct supervision on the basis of geographic criteria. In this context, the draft RTS introduces alternative quantitative thresholds to determine whether an obliged entity’s activities under the freedom to provide services are material. These thresholds are designed to capture both high-volume and high-customer business models and rely on data that should be readily available to obliged entities.
The draft RTS further sets out the risk assessment methodology that AMLA will apply when determining which eligible obliged entities will be subject to its direct supervision. This methodology is closely aligned with the framework used by supervisors for assessing entity-level ML/TF risk, thereby reducing administrative burden and promoting supervisory consistency.
In addition, the draft RTS introduces a group-wide risk scoring methodology based on a weighted average of entity-level residual risk scores, ensuring that high-risk entities and significant operations are appropriately reflected at group level.
On the basis of this methodology, AMLA will select the most complex and high-risk obliged entities with a significant presence within the EU, with the objective of ensuring a coordinated and consistent approach to cross-border AML/CFT supervision.
The draft RTSs apply to supervisors responsible for the AML/CFT supervision of credit institutions, financial institutions, and groups of credit and financial institutions, and reflect feedback received during a three-month public consultation conducted between March and June 2025.
The full text of this draft RTS may be accessed on AMLA’s website through the following link.