On 1st October 2026, the Anti-Money Laundering Authority (“AMLA”) has published a press release announcing that it has finalised three sets of Regulatory Technical Standards (“RTSs”) defining key measures obliged entities must apply to reduce money laundering and terrorist financing risks. The RTSs form part of the broader AML/CFT rulebook of the EU and provides the private sector with a common framework for meeting the requirements and mark a milestone towards a clear and consistent AML/CFT framework for the EU.
The RTSs cover three separate areas of AML/CFT requirements for obliged entities as per the below.
A. RTS on Customer Due Diligence (“CDD”)
This RTS outlines key requirements and provide greater clarity on customer and beneficial owner identification and verification requirements, the use of simplified due diligence measures in low-risk situations, acceptable verification sources, alternative non-face-to-face verification methods, and the use of electronic identification tools. This RTS also reinforces obligations relating to sanctions and politically exposed persons (“PEP”) screening, while introducing transitional compliance periods for existing customer relationships, reflecting a more harmonised and risk-based AML/CFT framework across the European Union.
B. RTS on criteria for identifying business relationships, occasional and linked transactions
This RTS aims to promote a consistent approach across the EU by clarifying when customer engagements should be treated as ongoing business relationships or occasional transactions, setting criteria for identifying linked transactions, and providing sector-specific guidance for various obliged entities, including lawyers, tax advisers, auditors and crypto-asset service providers.
C. RTS on group-wide minimum AML/CFT requirements
This RTS seeks to strengthen consistency across groups and certain structures by establishing minimum standards for governance, risk assessments, policies and procedures, information-sharing arrangements, staff training, and compliance oversight. This RTS also provides guidance on identifying the responsible parent undertaking within the EU and clarifies how group-wide AML/CFT requirements may apply to networks, partnerships and other structures operating under common ownership, management or compliance control.
D. Way forward
The RTS were developed in close cooperation with national supervisors within Member States and through feedback received from a vast range of stakeholders through written consultations and hearings. The final draft RTS have now been submitted to the European Commission for its approval and once adopted at this level and published in the Official Journal of the EU, the RTS will apply six months after their entry into force. For football agents and professional football clubs, the RTS will apply from 10 July 2029.
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