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GermanyWirtschaftsprüferkammer

AMLA finalises first AML standards; manual sanctions checks survive

AMLA sent standards on customer checks, business relationships and group-wide policies to the Commission for approval, keeping manual sanctions screening for smaller obliged entities.

By Taxxa AI OyPublished 6 October 2026

Financial Sector & Markets

The EU's Anti-Money Laundering Authority (AMLA) has finalised its first three technical regulatory standardsWPK and sent them to the European Commission for approvalWPK. The package, announced in AMLA's press release of 1 October 2026 and reported by the WPK on 6 October 2026, covers customer due diligence, the criteria for identifying business relationships and occasional transactions, and group-wide agreementsWPK Europa. AMLA draws its mandate from the EU anti-money-laundering package, which empowers and obliges it to draft the technical standards and guidelines that concretise and unify how obliged entities meet their duties.

For customer due diligence, the final text carries two reliefs the German audit profession had pressed for in the consultationWPK. An obliged entity may screen sanctions lists entirely by hand where its size, complexity and risk allow itWPK; the draft had provided for no exclusively manual screeningWPK. And the draft duty to verify the authenticity of identification documents has been dropped altogetherWPK WPK.

The group-wide agreements standard now addresses a narrower circle of addresseesWPK. The draft's very broad network concept had raised fears that networks whose members are only loosely connected with each other would also fall in scope. The criteria for determining the parent undertaking were revised as well, after criticism that annual turnover alone served as the sole fallback criterion.

The Wirtschaftsprüferkammer (WPK) took part in AMLA's public consultations on the due-diligence and group-wide standards and reports that several of its suggestions were taken up in the final texts. Under the EU Money Laundering Regulation, obliged entities apply AMLA's standards and guidelines, so the manual-screening proviso and the narrowed addressees are the operative signal for smaller firms and liberal professions: proportionality by size, complexity and risk rather than one automated control for all.

Legal basis: Verordnung (EU) 2024/1624, Article 19(9) (business relationships and occasional transactions) and Article 28(1) (customer due diligence), as implemented by the three AMLA final reports now before the Commission for approvalWPK.

Check whether your sanctions-list and customer-check procedures document the proportionality provisos (size, complexity, risk) instead of switching wholesale to automated controls.

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