AMLA Advances the EU Single Rulebook: Four Key AML Consultations Open

The European Union’s transition towards a harmonised anti-money laundering framework has entered a decisive phase. With the Anti-Money Laundering Authority (AMLA) now operational, the focus has shifted from legislative design to the detailed definition of supervisory expectations under the Anti-Money Laundering Regulation (AMLR).

In recent months, AMLA has significantly advanced this process through the publication of multiple consultations forming part of the Level 2 framework (i.e. detailed technical standards and guidelines that operationalise AMLR requirements in practice). These developments provide important insight into how the Single Rulebook will be applied across the EU.

Business-Wide Risk Assessment at the Centre of the Framework

A key recent milestone is the publication of draft Guidelines on Business-Wide Risk Assessment (BWRA), opened for consultation on 16 April 2026 with a deadline of 15 July 2026.

These guidelines reinforce the central role of the risk-based approach by requiring institutions to conduct a comprehensive and structured assessment of money laundering and terrorist financing risks across all relevant dimensions, including customers, products, services, transactions and geographic exposure.

Importantly, the BWRA is positioned not as a standalone exercise, but as the foundation of the entire AML/CFT framework. Institutions will be expected to demonstrate that their customer due diligence measures, transaction monitoring controls and internal policies are directly derived from and aligned with their risk assessment.

The draft also places increased emphasis on institutional ownership, requiring firms to move beyond generic or template-driven approaches and to ensure that methodologies are tailored, documented and supported by appropriate data.

Strengthening Group-Wide Consistency and Cross-Border Controls

Alongside the BWRA guidelines, AMLA has also published draft Regulatory Technical Standards addressing group-wide AML/CFT requirements, with consultation open until 15 June 2026.

These standards introduce harmonised expectations for the implementation of AML frameworks across groups, including subsidiaries and branches in third countries. In particular, they establish requirements to ensure that group-wide policies are consistently applied and that additional measures are implemented where local legal constraints may limit compliance.

This reflects a broader supervisory shift towards consolidated oversight and reinforces the expectation that risk management must be effective at both entity and group level.

Further Clarification of Customer Due Diligence and Transaction Scope

In February 2026, AMLA initiated a first wave of consultations on draft Regulatory Technical Standards addressing both Customer Due Diligence (CDD) and the criteria for identifying business relationships, occasional transactions and linked transactions (including applicable thresholds). Both consultations remain open until 8 May 2026.

The draft RTS on CDD set out detailed specifications on the application of due diligence measures in practice. This includes clarifying the distinction between standard, simplified and enhanced due diligence, as well as defining the data elements required to support these processes. These measures are expected to reduce divergence in CDD practices across Member States and establish a more consistent and harmonised baseline for compliance.

In parallel, the RTS on transaction and relationship criteria address how institutions determine the nature and scope of customer interactions. By providing clearer definitions of business relationships, occasional transactions and linked transactions, alongside associated thresholds, these standards aim to remove ambiguity in classification. This will have a direct impact on onboarding frameworks, transaction monitoring logic and the consistent identification of AML obligations.

Taken together, these consultations illustrate a clear regulatory direction. The AMLR framework is evolving towards greater harmonisation, increased prescriptiveness and stronger alignment between risk assessment, due diligence and ongoing monitoring.

How cleversoft Supports AMLR Readiness

At cleversoft, we continuously monitor regulatory developments driven by AMLA and the evolving EU AML framework, ensuring that emerging requirements are translated into practical, scalable solutions for our clients.

As AMLA progresses the definition of the Single Rulebook, we are continuously analysing consultations, assessing their operational impact and incorporating these requirements into our product suite in a structured and timely manner, well in advance of the July 2027 application date. By embedding regulatory requirements directly into system functionality, cleversoft enables clients to remain continuously aligned with supervisory expectations and to achieve sustainable, future-proof compliance in an increasingly harmonised regulatory landscape.

Learn more about how we support AMLR 2027 readiness here:
AMLR 2027: One EU Rulebook. One Platform. Total Compliance. – cleversoft

Source: Public Consultations – Authority for Anti-Money Laundering and Countering the Financing of Terrorism