EBF response to AMLA’s draft Guidelines on Ongoing Monitoring of a Business Relationship

Brussels, 7 September 2026 – The European Banking Federation (EBF) has submitted its feedback on AMLA’s draft Guidelines on Ongoing Monitoring of a Business Relationship under Article 26(5) of the AMLR.

The EBF supports AMLA’s objective of providing a consistent framework for ongoing monitoring, while emphasising that the Guidelines should remain firmly anchored in a risk-based and proportionate approach. In our view, obliged entities should retain sufficient flexibility to determine the appropriate depth and intensity of monitoring based on the risks associated with the business relationship, rather than applying uniform or overly prescriptive requirements.

We also stress that ongoing monitoring should not result in a de facto continuous KYC process, with the repeated collection, verification or updating of customer information in the absence of a relevant trigger or risk-based justification. Event-driven and periodic reviews should be clearly distinguished and designed to avoid unnecessary duplication, with monitoring outputs and relevant changes informing the scope of further review where appropriate.

Finally, the EBF calls for a clear and proportionate approach to transaction monitoring, including ensuring that the Guidelines do not introduce a general expectation of pre-transaction or real-time monitoring beyond the requirements of the AMLR. We also emphasise the importance of technological neutrality, allowing obliged entities to determine the appropriate combination of manual, semi-automated and automated controls according to their risk profile, business model and operational circumstances.

Read the full document here

For more information:

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

Giulia Verde, Policy Adviser/Executive Coordinator, Tax and Compliance – g.verde@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.