A&O Shearman | FinReg | AMLA consults on draft guidelines on ongoing monitoring of business relationships
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  • AMLA consults on draft guidelines on ongoing monitoring of business relationships

    3 June 2026
    The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has launched a consultation on draft guidelines on ongoing monitoring of business relationships under Article 26(5) of Regulation 2024/1624. The guidelines aim to ensure a proportionate, risk based and effective application of monitoring obligations across all obliged entities and set out key principles including:
    • Expectations for updating customer information through periodic and event driven reviews.
    • The sources of information that may be used alongside non exhaustive lists of factors to assess during periodic customer information reviews and event trigger reviews.
    • How monitoring frameworks should be designed and implemented to detect unusual or suspicious activity, using appropriate manual or automated controls.
    They further reflect the need for clear governance, adequate documentation, appropriate staff training, and the responsible use of advanced analytical tools, supported by effective human oversight, where appropriate. The deadline for comments is 3 September, with a public hearing scheduled for 2 July. Final guidelines are expected in Q4.

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