AMLA publishes three sets of final draft RTS under EU AML package

The EU Anti-Money Laundering Authority (AMLA) has published three sets of final draft regulatory technical standards (RTS) defining key measures companies and professionals must apply to reduce anti-money laundering and countering terrorist financing (AML/CTF) under the EU AML Regulation ((EU) 2024/1624) (AMLR). For more background on the package, you may like to read our article "AML playbook: the new EU AML/CTF package". The three final draft RTS each cover a distinct area of AML/CTF requirements for the private sector:

• Draft RTS on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries under Articles 16(4) and 17(3) of the AMLR. They are accompanied by two fact sheets covering group-wide requirements and legal impediments in third countries. The RTS set out minimum requirements for effective group-wide AML/CTF arrangements, including governance, risk management, internal controls, and secure information sharing. The RTS were previously consulted on in April.
• Draft RTS on customer due diligence (CDD) under Article 28(1) of the AMLR. They specify in detail how CDD requirements should be applied, including the information and documents to be collected. The RTS are accompanied by a fact sheet. They were previously consulted on in February.
• Draft RTS on criteria for identifying business relationships, occasional transactions and linked transactions as well as lower thresholds under Article 19(9) of the AMLR. They form the structural basis upon which CDD obligations apply. The RTS set out how companies and professionals should distinguish between the business relationships and occasional transactions, as well as how to identify linked transactions so that CDD thresholds are applied consistently. The RTS are accompanied by a fact sheet. They were previously consulted on in February and AMLA has made some revisions to improve clarity.

The final draft RTS will be submitted to the European Commission for adoption. Once adopted, they will be published in the Official Journal of the European Union and come into force 20 days later. They are expected to apply six months after they enter into force, except for specified provisions which will apply from 10 July 2029.

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