EU AMLA Anti-Money Laundering Brief

Headline

AMLA submits three final draft RTS to the European Commission covering CDD, business relationships, and group-wide AML/CFT arrangements

Executive Summary

AMLA has submitted to the European Commission three sets of draft regulatory technical standards (RTS) establishing AML/CFT requirements for obliged entities across the EU. The standards cover customer due diligence, the distinction between business relationships and occasional transactions, and group-wide governance arrangements. Once adopted and published in the Official Journal of the EU, they are proposed to apply six months after entry into force.

Bottom Line

AMLA has submitted three final draft RTS to the European Commission covering customer due diligence, business-relationship and transaction thresholds, and group-wide governance. The standards carry no binding force until the Commission adopts them and publishes them in the Official Journal of the EU. Once in force, the general application date is proposed as six months after entry into force, with football agents and professional football clubs subject to a separate proposed application date of 10 July 2029. Cresthaven reading: obliged entities with group structures spanning third-country subsidiaries or branches face the most operationally complex set of requirements across the three standards, given the governance, risk management, and information-sharing minimums the draft group-wide RTS sets out.

Key Regulatory Signals

• Customer Due Diligence Standards Define Collection and Verification Requirements: The draft RTS on customer due diligence specifies the information obliged entities must collect and verify, covering proportionate measures for lower-risk situations, non-face-to-face verification, electronic identification, and screening of politically exposed persons, their family members, and close associates.
• Business Relationships and Occasional Transactions Standard Sets Threshold Criteria: The draft RTS on business relationships and occasional transactions defines how companies and professionals should distinguish between the two categories and how to identify linked transactions, so that customer due diligence thresholds are applied consistently across obliged entities.
• Group-Wide Standard Establishes Minimum Governance Requirements: The draft RTS on group-wide arrangements sets minimum requirements for governance, risk management, internal controls, and secure information sharing within groups. Cresthaven reading: groups with cross-border structures, including subsidiaries and branches in third countries, face a defined set of minimum requirements under these draft standards once adopted.
• Football Sector Receives a Deferred Application Date: For football agents and professional football clubs, the standards are proposed to apply from 10 July 2029, a date stated explicitly in the source, while the general application date is six months after entry into force following European Commission adoption and publication in the Official Journal of the EU.
• Submission to the European Commission Initiates the Adoption Process: The final draft standards have been submitted to the European Commission. They carry no binding force until adopted by the Commission and published in the Official Journal of the EU.

Regulatory Delta

• No direct AMLA precedent exists for this submission.
• The standards have advanced from consultation and stakeholder hearings into final draft form, moving the EU AML/CFT single rulebook from proposed to submitted status. Commission adoption remains pending.
• The European Commission must adopt and publish the standards in the Official Journal before they carry binding force. The next material step therefore lies outside AMLA's direct control.

Materiality Classification

MEDIUM — Final draft RTS submitted to the European Commission for adoption; standards are not yet binding, but the submission advances a sector-wide AML/CFT compliance baseline for all EU obliged entities and signals the shape of forthcoming binding requirements.

Time Horizon

implementation — 2029-07-10

Intelligence Outlook

Monitor the European Commission for adoption of these draft standards and publication in the Official Journal of the EU, which triggers the six-month countdown to the proposed application date.