AMLR: What the new RTS mean for your firm

The AMLR applies from 10 July 2027. Understand what AMLA’s final draft Regulatory Technical Standards mean for your customer due diligence, screening and group-wide AML/CFT controls, and where to begin your gap analysis.

In this webinar, we provide a practical interpretation of the final draft RTS, which now go to the European Commission for adoption. Customer remediation and screening upgrades take time, so early planning helps you sequence the work and allocate resources.

If you are an MLRO, head of compliance or financial crime, or a senior manager at an EU-regulated firm or group with EU operations, the session will help you identify your implementation priorities. The discussion covers banking, payments, e-money, crypto, FX, remittance and gambling.

Customer due diligence and verification

Review expanded identification data, alternative verification and the safeguards you need to consider when using document and selfie checks.

Existing customer remediation

Plan your back-book review around the proposed one-year timeline for higher risk customers and five-year timeline for other customers.

Sanctions and PEP screening

Assess screening coverage, including beneficial owners and controllers, original and Latin scripts, aliases, trade names, wallet addresses and regular re-screening.

Business relationship tests

Understand sector-specific tests for remitters, FX and crypto exchanges, and gambling providers, including repeated and linked transactions.

Group-wide AML/CFT controls

Examine group frameworks, intra-group data sharing, EU oversight arrangements and your response where third country laws prevent AMLR compliance.

Your gap analysis priorities

Identify the policy, data, technology and governance changes to prioritise as you prepare for the AMLR application date of 10 July 2027.

When should I start my gap analysis?

Start now so you can sequence customer remediation, screening upgrades and governance changes before the AMLR applies on 10 July 2027. The session explains the separate RTS timetable: each RTS applies six months after entering into force, which follows 20 days after Official Journal publication.

Can I continue using document and selfie checks?

The final draft RTS are likely to treat document and selfie checks as an alternative solution, an exception requiring justification. We explain the implications of demonstrating the five safeguards to your supervisor and why you should discuss the requirements with your identity verification provider now.

How should I plan existing customer reviews?

Build your remediation plan around the final draft RTS timelines: one year for higher risk customers and five years for other customers. The webinar helps you consider the work involved in updating your existing customer base and prioritising the data, verification and screening changes your firm needs.

What changes should I consider for screening?

Assess how your sanctions screening covers customers, beneficial owners and anyone who controls them. The session examines names in original and Latin script, aliases, trade names and wallet addresses, alongside regular re-screening of your customer base, so you can identify changes to discuss with your provider.

When do repeated transactions indicate a business relationship?

If you operate in remittance, bureaux de change or cryptoasset services, the final draft RTS introduce specific tests. We discuss three or more transactions within 12 months as an indicator of a business relationship, together with the one-month window for linked transactions and the implications for your controls.

What if my group’s head office is outside the EU?

The final draft RTS address an EU parent designation for groups headquartered outside the EU. If you have multiple EU entities, consider which is best placed to oversee EU operations and notify its supervisor. The session also covers EU heads of structure for commonly controlled networks and franchises.

About fscom

fscom Compliance Maturity Specialists™ help you benchmark your financial crime framework against regulatory requirements and peer practice. Our regulatory advisory, audit and remediation support helps you turn those findings into practical improvements in compliance maturity.

This webinar provides a general summary and interpretation of the final draft RTS. It is not a complete or definitive statement of the law. Specific advice should be obtained where appropriate, and final requirements remain subject to adoption.

On-demand AMLR webinar