AMLA final report: draft RTS on business relationships and linked transactions

Key takeaways

• Business relationships trigger CDD independently of transaction value; occasional transactions require a separate assessment of applicable thresholds and other triggers.
• Linked occasional transactions are assessed together for the relevant threshold. Linking can involve different customers and does not itself establish suspicion.
• The AMLR definitions control the assessment. Draft criteria support judgement; one matching indicator does not automatically establish a relationship or a link.
• The proposed three-transactions-in-12-months criterion concerns currency exchange, money remittance and specified crypto-asset services, rather than every obliged entity.
• The proposed one-month criterion for linked transactions concerns those same specified services. It is not a universal deadline or permission to disregard other relevant connections.
• For services connected to transactions, the underlying transaction value matters for thresholds, excluding transaction or service fees.
• Ongoing access to covered services can indicate duration. A subscription solely to an informational newsletter does not provide that access.
• The final draft proposes application six months after entry into force. The AMLR's general 10 July 2027 application date does not establish this RTS's application date.

What changed

The report advances the instrument consulted on from 9 February to 8 May 2026. The consultation and final report are successive stages of the same Article 19(9) RTS development; the final report is dated 30 September 2026, preceding the 1 October announcement.

Compared with the consultation text, draft Article 2(1) focuses on ongoing access to AML/CFT-covered services without limiting the criterion to online registration. Article 2(2) expressly addresses services requiring multiple actions over a substantial period for the professional service providers specified in AMLR Article 3(3)(a)-(d) and (l). Voluntary membership at physical gambling premises and conditional obligations in football transfers are also clarified.

Draft Article 3 expressly requires an overall assessment of relevant facts and circumstances. It addresses connections between customers, purchases and channels, with certain criteria dependent on available information. The three-transactions and one-month criteria were already present in the consultation proposal; they are retained sector-specific criteria.

Draft Article 4 replaces the consultation proposal's fixed 10 July 2027 application date with six months after entry into force. Entry into force would be on the twentieth day after Official Journal publication, with a proposed football-sector application date of 10 July 2029. An absolute general RTS application date cannot yet be calculated.

Why it may matter

An occasional transaction is a covered transaction or a connected service outside a business relationship. A business relationship involves a professional customer engagement with expected or acquired repetition or duration; a written contract is not essential. The assessment must satisfy the full AMLR definition. A process based solely on individual payment amounts can miss the point at which CDD is required.

When the AMLR applies, Article 19 provides a general EUR 10,000 occasional-transaction threshold, EUR 1,000 for covered transfers of funds by credit and financial institutions other than CASPs, and EUR 1,000 for CASP occasional transactions. CASPs must apply at least customer identification and identity verification below EUR 1,000. Gambling has a EUR 2,000 threshold for winnings, stakes or both. Occasional cash transactions of at least EUR 3,000 require at least identification and verification, subject to the national cash-limit exception in Article 19(4). These thresholds do not displace CDD triggers for business relationships, suspicion or other Article 19 circumstances.

As an illustration, two payments of EUR 4,800 and EUR 5,500 total EUR 10,300. If an assessment establishes that they are linked and the general AMLR threshold applies, treating each payment separately would produce the wrong CDD result. The same purchase can support the assessment, but the conclusion must address the relevant facts. Conversely, a shared customer identifier or IP address alone should not become a rule that every transaction is linked.

Preparation should connect onboarding, transaction records and staff decisions without treating every linked payment as suspicious or every below-threshold payment as exempt. Review this proposal alongside the separate Article 28(1) CDD RTS and Article 26(5) ongoing-monitoring guidelines work. The latter's consultation closed on 3 September 2026; it is a separate instrument, rather than part of this final report.

Who may be affected

The proposal concerns obliged entities within the AMLR's scope, including covered financial institutions and specified non-financial businesses and professions. Relevant sectors include currency exchange, money remittance, crypto-asset services, professional services, real estate, gambling, investment migration and covered football-transfer activities. Scope depends on the applicable definitions, activities and exemptions. Insurance coverage concerns the relevant life and investment-related business; legal professionals are covered for specified activities.

The numerical criteria in draft Articles 2(4) and 3(2) apply to currency exchange, money remittance and crypto-asset services referenced in MiCA Article 3(1)(16)(c), (d) and (j). They do not apply to every activity of every CASP. AML/CFT compliance, onboarding, payments, technology, data governance, legal, assurance and supervisory teams should assess the implications within their respective roles.

Practical considerations

• Map each covered customer journey to business-relationship or occasional-transaction assessment. Record the expected duration, repetition and access to services before selecting a threshold workflow.
• Build a legal requirements matrix separating currently applicable rules, the AMLR and proposed RTS criteria. Identify the entity, service, jurisdiction, CDD measures and implementation dependency for each rule.
• Check sector applicability before configuring numeric indicators. Keep three transactions in 12 months and the one-month criterion out of unrelated services, and retain a documented assessment beyond numeric matches.
• Test first-contact cases where continuing services are already expected. A process should not postpone a business-relationship assessment until a third transaction simply because that numerical indicator exists.
• Review identifiers and transaction records across the entity's branches, agents and digital channels. Test split purchases, coordinated customers, common orders and transactions whose completion depends on earlier transactions.
• For professional services, verify how the underlying transaction value is recorded and distinguished from fees. Assign an owner to missing-value cases rather than defaulting to the invoice for the service.
• Document why transactions are or are not linked, the relevant information and the aggregation result. Keep the linkage decision separate from any suspicion assessment and associated escalation.
• Use information lawfully available or independently required. Do not interpret the draft as an instruction to collect new family or device data solely to identify links, or as a waiver of existing CDD duties.
• Train staff using realistic paired cases: continuing engagement versus a one-off service, linked instalments versus unrelated payments, and informational registration versus access to covered services.
• Track Commission adoption, scrutiny, Official Journal publication and any changes to the final text. Calculate implementation dates from the adopted provisions before committing to a definitive RTS deadline.

These considerations support professional review and do not constitute legal advice.

Legal basis and references

Official sources

• AMLA official source
• AMLA factsheet accompanying the Article 19(9) final draft
• AMLR: Regulation (EU) 2024/1624
• AMLAR: Regulation (EU) 2024/1620, consolidated 10 November 2025
• AMLA announcement of the final private-sector drafts, 1 October 2026
• AMLA Article 19(9) consultation history
• AMLA February 2026 consultation paper: earlier proposed text
• AMLA regulatory instruments register
• AMLA ongoing-monitoring guidelines consultation: separate instrument