What happened on 1 October
AMLA finalised three draft Regulatory Technical Standards for the private sector: criteria for business relationships, occasional and linked transactions; Customer Due Diligence; and group-wide AML/CFT requirements. This is a major step towards the Single Rulebook. The final drafts are transmitted to the Commission for subsequent adoption and publication: AMLA finalisation does not mean immediate applicability.
AMLA’s 1 October release proposes application six months after entry into force, following Commission adoption and Official Journal publication. This proposal is not an immediately applicable deadline for every private operator.
Why CDD deserves attention now
The CDD package reaches the core of operations: information to collect and verify, proportionality in lower-risk situations, non-face-to-face verification, electronic identification and screening of PEPs, family members and close associates. The practical question is not only what the text says, but which data, decisions and controls in the current process need to be mapped against the emerging standard.
Occasional and linked transactions
Distinguishing an ongoing relationship from an occasional transaction affects when CDD is triggered. Linked transactions also matter because economically connected activity should not be assessed as unrelated individual payments simply because it is fragmented. Effective controls therefore need to connect parties, timing, amounts and purpose rather than check a threshold in isolation.
Groups and Home-Host cooperation
Group-wide requirements concern governance and controls within the group; the Home-Host RTS instead governs cooperation between supervisors of cross-border groups. They are connected but distinct: one concerns the organisation, the other information exchange and supervisory coordination.
What remains open
The consultation on the methodology for assessing inherent and residual risk of non-financial obliged entities closed on 27 September and still states that results will follow. The same is true of the draft ongoing-monitoring Guidelines consultation, which closed on 3 September. The cross-border FIU consultation closed on 6 October; AMLA states that it imposes no direct obligations on private companies.
The 2 October signal: simplified CDD
AMLA invited obliged entities and representative bodies to sectoral roundtables on simplified customer due diligence. Feedback will inform future Guidelines. This is important because the new framework is not only about more intensive controls: it is also about applying simplified measures consistently and proportionately where risk is genuinely lower.
Practical scenario
One obliged entity starts implementing every element found in AMLA consultations immediately. Another decides to wait until July 2027. Both approaches can fail: the first confuses drafts, finalised standards and applicable law; the second loses time on gaps that can already be identified.
A useful roadmap separates four columns: confirmed Level 1 requirement; AMLA-finalised standard; matter still under consultation or development; internal process affected. Each line can then be assigned an owner, expected evidence and review date.
What to check now
Without anticipating requirements that are not yet final, October 2026 is a sensible point to test whether the control architecture can absorb Level 2 changes without a last-minute redesign.
- CDD: data, verification, PEP screening, non-face-to-face processes and decision traceability.
- Occasional/linked transactions: ability to connect activity sharing parties, purpose, timing or funds.
- Group-wide: roles, information flows, local exceptions and accountability.
- Ongoing monitoring: customer updates and consistency between profile and activity over time.
- Regulatory governance: documented distinction between applicable text, finalised standards and proposals still evolving.
Sources and references
Informational content. It does not replace an assessment of a specific case.
AMLA — Key standards for the private sector, 1 October 2026AMLA — Home-Host Supervisory Cooperation, 1 October 2026AMLA — Simplified CDD roundtables, 2 October 2026AMLA — Non-financial inherent/residual risk consultationAMLA — FIU cross-border information exchange consultationAMLA — Ongoing monitoring consultation