The European Banking Federation has submitted feedback on AMLA’s draft regulatory technical standard on criteria for identifying business relationships, occasional and linked transactions, and lower thresholds under Article 19(9) AMLR. It argues that, in its current form, the draft would create legal and operational uncertainty for obliged entities and should instead set clearer, more proportionate and genuinely risk based criteria that function as risk indicators rather than automatic triggers for AML/CFT obligations. The response highlights concerns that the broadened AMLR definition of business relationship, combined with the negative definition of occasional transaction, could bring low risk situations into scope and lead to divergent interpretations across Member States, including where an institution’s gatekeeper role is not engaged. It also says several criteria for identifying linked transactions are too broad or insufficiently defined, creating operational challenges, excessive false positives and potential data protection concerns.
European Banking Federation2026-05-07
European Banking Federation submits feedback urging clearer risk based AMLA criteria for business relationships and linked transactions
The European Banking Federation has submitted feedback on the Anti-Money Laundering Authority’s draft regulatory technical standard on criteria for identifying business relationships, occasional and linked transactions, and lower thresholds under Article 19(9). It warns that the draft would create legal and operational uncertainty, pull low-risk situations into scope, and lead to divergent interpretations across Member States, and calls for clearer, more proportionate, risk-based criteria that operate as risk indicators rather than automatic triggers for AML/CFT obligations.