European Banking Federation submits feedback on AMLA customer due diligence RTS seeking more proportionate rules

The European Banking Federation has submitted feedback on the Anti-Money Laundering Authority draft regulatory technical standards on customer due diligence under Article 28(1) of Regulation (EU) 2024/1624, arguing that the rules should remain proportionate, risk based and operationally workable. It calls for greater flexibility in customer identification and verification, including avoiding unnecessary re-verification where identity has already been properly established, taking a pragmatic approach to data points such as place of birth and multiple nationalities, and allowing continued use of existing remote identification solutions until eIDAS 2.0 tools are fully deployed. The feedback also seeks clearer and narrower definitions of Senior Managing Officials and persons acting on behalf of customers so that obligations focus on individuals with legal authority to bind the company and remain aligned with Level 1 requirements. It urges a genuinely risk-based approach to ownership and control structures rather than automatic classifications of complexity based only on the number of ownership layers, asks to avoid disproportionate customer due diligence obligations for end-investors and underlying clients, and requests confirmation that perpetual KYC is sufficient in low-risk cases without mandatory periodic customer outreach or proactive data updates where no risk indicators exist. The federation also stresses the need for phased implementation of the RTS.