AMLA Consults on Group-Wide AML Frameworks and BWRA Guidelines

April 21, 2026

AMLA consults on group-wide requirements and guidelines for BWRAs

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The EU Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) has launched two consultations on draft measures setting out requirements for business‑wide risk assessments (BWRAs) and group‑wide anti-money laundering and countering the financing of terrorism (AML/CFT) frameworks under the EU Anti‑Money Laundering Regulation (AMLR).

The first consultation specifies draft regulatory technical standards (RTS) under Articles 16(4) and 17(3) of the AMLR, setting minimum standards for the design and implementation of group‑wide AML/CFT frameworks. They address organisational aspects of group wide AML/CFT requirements, provisions on information sharing within groups, criteria for identifying the parent undertaking in the Union where multiple obliged entities are linked to a third country head office, and the extension of group wide requirements to structures other than groups (which is particularly relevant to the non financial sector). The draft RTS also cover additional measures and requirements where branches or subsidiaries operate in third countries. AMLA proposes a single set of RTS to cover both Article 16(4) and Article 17(3) mandates. The deadline for comments is 15 June, with a public hearing scheduled for 20 May. Feedback will be considered with the final draft RTS due to be submitted by 30 September.

The second consultation covers draft guidelines under Article 10(4) AMLR, specifying the minimum requirements for the content of obliged entities' BWRAs and additional sources of information to be considered when carrying out the BWRA. The guidelines are intended to assist with identifying and assessing risks of AML/CTF and the non implementation and evasion of targeted financial sanctions. To this end, AMLA proposes four minimum requirements applicable across all sectors, while emphasising that obliged entities retain responsibility for ensuring their BWRA is proportionate to their size, business model, complexity and risk profile. The deadline for comments is 15 July, with a public hearing scheduled for 28 May. AMLA will consider feedback and issue the final guidelines in Q4.

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