EBF feedback on AMLA draft guidelines on Business-wide risk assessment under Article 10 (4) of Regulation (EU) 2024/1624
Brussels, 17 July 2026 – The European Banking Federation (EBF) supports AMLA’s objective of fostering a consistent approach to business-wide risk assessments, as set out in its response to AMLA’s draft Guidelines on Business-wide Risk Assessment under Article 10(4) of the AMLR.
At the same time, the EBF emphasises that the Guidelines should remain firmly grounded in the risk-based and proportionate approach established by the AMLR. Several provisions would benefit from greater flexibility, enabling institutions to apply methodologies that are proportionate to their individual risk profiles and the nature, scale and complexity of their activities.
The EBF also encourages AMLA to provide greater clarity on the practical application of the Guidelines to facilitate consistent implementation across cross-border banking groups while avoiding unnecessary duplication and overly prescriptive compliance processes. The Guidelines should recognise the diversity of cross-border banking groups and allow institutions to conduct business-wide risk assessments in a manner that reflects their existing governance frameworks, operating models, and applicable local legal and supervisory requirements
Finally, we recommend clarifying expectations regarding the use of risk factors, information sources and data points, making clear that institutions may rely on those that are relevant and appropriate to their specific risk profiles rather than applying a uniform set of requirements. This would support the practical, effective and proportionate implementation of the Guidelines while preserving the flexibility that is fundamental to a genuinely risk-based approach.
For more information:
Roger Kaiser, Head of Tax and Compliance – r.kaiser@ebf.eu
Anna Maria Nowak, Policy Advisor – Tax and Compliance – am.nowak@ebf.eu
About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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