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AMLA Launches Two Public Consultations on AML/CFT Group-Wide Requirements and Business Risk Assessment

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Summary

AMLA has launched two public consultations: draft guidelines under AMLR Article 10(4) on business-wide AML/CFT risk assessment, with a public hearing on 28 May 2026 and comments due 15 July 2026; and draft regulatory technical standards under Articles 16(4) and 17(3) of the AMLR on group-wide minimum requirements for subsidiaries and branches in third countries, with a hearing on 20 May 2026 and comments due 15 June 2026. AMLA is also advancing preparations for its 2027 selection exercise to identify up to 40 high-risk financial institutions for direct EU-level supervision from 2028, supported by an EBA-published draft taxonomy and data model. An updated data collection template for the 2026 testing and calibration exercise adds Kosovo to country lists and includes credit providers as an entity type.

Why this matters

Obliged entities subject to AML/CFT obligations should allocate time to review both consultation documents: the group-wide RTS has a tight 15 June 2026 deadline, while the business-wide risk assessment guidelines consultation closes 15 July 2026. Entities operating subsidiaries or branches in third countries should pay particular attention to the RTS requirements, as these will impose obligations to adapt group-level AML/CFT policies and control functions to cross-border contexts.

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What changed

AMLA has launched two public consultations on draft instruments under the AMLR. The first covers business-wide risk assessment guidelines under Article 10(4), setting minimum expectations for obliged entities across financial and non-financial sectors to identify ML/TF risks. The second covers draft RTS under Articles 16(4) and 17(3) on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries, requiring groups to maintain a consolidated AML/CFT risk view across their entire organisation. AMLA has also published updates on its 2027 selection exercise to place up to 40 high-risk entities under direct EU-level supervision from 2028. Subject persons (obliged entities) subject to AML/CFT obligations should review both consultation documents and submit feedback by the stated deadlines. The 2026 testing and calibration exercise template has been updated to include Kosovo and credit providers; entities already submitted do not need to resubmit.

What to do next

  1. Review the consultation document on draft guidelines on business-wide risk assessment and submit feedback by 15 July 2026, 23:59
  2. Review the consultation document on draft RTS concerning group-wide requirements and submit feedback by 15 June 2026, 23:59

Archived snapshot

Apr 22, 2026

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Latest Updates from AMLA

April 22, 2026

Latest Updates from AMLA

The FIAU would like to bring to your attention various updates from the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA). AMLA has launched two public consultations on draft instruments concerning group-wide requirements and business-wide risk assessment and has also published updates regarding the next steps in preparing for the selection of obliged entities for direct supervision starting in 2028.

Draft Guidelines on business-wide risk assessment.

AMLA has launched a public consultation on draft guidelines under AMLR Article 10(4).  It sets out the minimum expectations for all obliged entities in identifying risks of money laundering and terrorist financing across their operations. These guidelines aim to support entities in making informed, risk-based decisions on how to manage their specific risk exposure across both the financial and non-financial sectors.

AMLA has also scheduled an online public hearing on these draft guidelines on 28 May 2026 between 10:00 and 12:00 CET. Further details on the public hearing will be made available by AMLA in due course. For further information on these draft Guidelines, reference should be made to the following link.

The FIAU encourages relevant subject persons (obliged entities) to actively participate in this consultation process by reviewing the consultation document and submitting their feedback through the following link by  15 July 2026, 23:59.

Draft RTS on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries.

AMLA has launched a public consultation on draft regulatory technical standards (RTS) concerning group-wide requirements. The draft RTS, issued under Articles 16(4) and 17(3) of the AMLR, set out minimum standards for group-wide AML/CFT frameworks, including in cross-border contexts and where obliged entities operate in third countries.

These requirements aim to ensure that groups maintain a consolidated view of money laundering and terrorist financing risks across their entire organisation and adapt their policies, procedures, and control functions accordingly.

AMLA has scheduled an online public hearing on this draft RTS on the 20th of May 2026 between 10:00 and 12:00 CET. Additional information on the public hearing will be made available by AMLA in due course.

For further information on these draft Guidelines, reference should be made to the following link.

The FIAU encourages relevant subject persons (obliged entities) to actively participate in this consultation process by reviewing the consultation document and submitting their feedback through the following link by 15 June 2026, 23:59.

When submitting feedback, AMLA encourages stakeholders to ensure their comments are clear and constructive. To be most effective, comments should: directly respond to the question posed, clearly indicate the relevant point, provide a well-supported rationale with evidence, and suggest alternative regulatory options for consideration.

AMLA advances preparations for the 2027 selection exercise

AMLA is progressing preparations for its first selection of financial institutions to be placed under direct EU-level supervision from 2028. Up to 40 high-risk entities will be identified using a risk-based methodology.

To support this, the European Banking Authority (EBA) has published a draft taxonomy and data model for consultation to identify obliged entities that will fall under AMLA’s direct supervision. The first selection exercise will take place in 2027. The draft is published on EBA’s website and should be read alongside the templates and instructions AMLA published for the testing and calibration exercise.

Updated template for the 2026 testing and calibration exercise

AMLA has published an updated version of the data collection template for the 2026 testing and calibration exercise, launched on 16 March 2026. Only entities that are credit providers and/or have activities in Kosovo are required to use this new template.

The update corrects two omissions in the original template:

  • Kosovo has been added to the list of countries.
  • Credit providers have been added to the list of entity types. Both the updated and original templates will be accepted. Entities that have already submitted their files are not required to resubmit.

More information on these updates can be found on AMLA’s website through this link.

AMLA

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Last updated

Classification

Agency
FIAU
Published
April 22nd, 2026
Instrument
Notice
Branch
Executive
Joint with
AMLA EBA
Legal weight
Non-binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Financial advisers Banks Insurers
Industry sector
5221 Commercial Banking
Activity scope
AML/CFT compliance Business risk assessment Group-wide risk frameworks
Geographic scope
European Union EU

Taxonomy

Primary area
Anti-Money Laundering
Operational domain
Compliance
Compliance frameworks
BSA/AML
Topics
Banking Securities

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