EBF feedback on the AMLA Draft Regulatory Technical Standard on business relationships

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Brussels, 7 May 2026 – The European Banking Federation (EBF) has submitted its feedback on the AMLA Draft Regulatory Technical Standard on criteria for identifying business relationships, occasional and linked transactions, and lower thresholds under Article 19(9) AMLR.

In its current form, the draft RTS creates significant legal and operational uncertainty for obliged entities. The banking sector is calling for a clearer, more proportionate and genuinely risk-based approach, ensuring that the criteria serve as risk indicators rather than automatic triggers for AML/CFT obligations.

In particular, the EBF is concerned that the broadened definition of “business relationship” under the AMLR, combined with the negative definition of “occasional transaction”, may lead to an overly broad scope and divergent interpretations across Member States, including in low-risk situations that do not involve the institution’s gatekeeper role.

The EBF also highlights that several criteria for identifying linked transactions are too broad or insufficiently defined, creating operational challenges, excessive false positives and potential data protection concerns.

For more information:

Roger Kaiser, Head of Tax and Compliance – r.kaiser@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.