Scope first, procedure second
Accountants, lawyers and notaries do not perform the same activities and are not subject to AML duties for every engagement without distinction. The first step is to map the services that fall within the relevant framework, jurisdiction and any applicable exceptions. Only then is it useful to design a proportionate customer due-diligence process.
What to prepare before 2027
Regulation (EU) 2024/1624 makes the European framework more uniform and most provisions apply from 10 July 2027. A useful review links each relevant requirement to the service and the firm’s actual process.
- Service catalogue and criteria identifying when AML duties apply.
- Risk assessment consistent with the customers, countries, structures and transactions handled.
- Method for documenting ownership and control, including discrepancies requiring review.
- Roles, escalation and documented decisions, including unresolved situations.
Practical scenario
A firm receives an engagement combining corporate advice, contractual support and execution-related activities. Before opening the same AML file for the whole relationship, it should distinguish which services fall within the applicable perimeter, which parties require identification and which event changes the risk. Control quality starts with defining the engagement correctly: a longer procedure does not fix a wrongly scoped perimeter.
Sources and references
Informational content. It does not replace an assessment of a specific case.
Regulation (EU) 2024/1624European Commission — EU AML/CFT framework