Consultation on the draft RTS on criteria for identifying business relationships, occasional and linked transactions and lower thresholds

AMLA’s open public consultations are open to all stakeholders with an interest in the EU’s anti‑money laundering and countering the financing of terrorism (AML/CFT) framework. We particularly welcome contributions from financial institutions and designated non-financial businesses and professions, civil society organisations, academia, sectoral federations and organisations, and other relevant parties.

Public input on this draft RTS is essential to ensure that the criteria it contains are effective and can be applied by all obliged entities in practice.

This draft RTS establishes criteria for identifying business relationships, occasional transactions, and linked transactions. Distinguishing between business relationships and occasional transactions is a fundamental step in applying the AML/CFT framework. For business relationships, obliged entities must always perform customer due diligence (CDD). For occasional transactions, CDD is required only when the transaction value exceeds certain thresholds. Identifying linked transactions is equally important, as it prevents criminals from circumventing these thresholds by structuring their activities across multiple smaller transactions.

The criteria in this draft RTS apply to all obliged entities across both the financial and non-financial sectors. While some criteria are universal, others are tailored to specific categories of obliged entities.

AMLA has the option under the regulation to set additional lower CDD thresholds for occasional transactions. At this stage, AMLA has chosen not to exercise this option.

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To respond to the consultation, please click on the link below.