AMLR article guide: what each key article does

This is the hub for our article pages. Article numbers below are checked against the text of Regulation (EU) 2024/1624. Where we have a dedicated page, we link it.

Scope and groups (Chapter I and II)

• Article 2 defines the terms. Point (42), “parent undertaking”, matters for groups: see Article 2(1)(42).
• Article 3 lists obliged entities. Beyond banks and the usual financial firms, it covers auditors, notaries, trust and company service providers, estate agents, gambling providers, crowdfunding service providers, investment migration operators and football agents and clubs, among others.
• Article 10 is the business-wide risk assessment. Article 16 sets group-wide requirements for parent undertakings.

Customer due diligence (Chapter III)

• Article 19 applies the measures; Article 20 lists them. See Article 20.
• Article 21 deals with what to do when you cannot complete due diligence.
• Article 22 governs identification and verification: Article 22.
• Articles 25 and 26 cover the purpose of the relationship and ongoing monitoring.
• Article 28 is the empowerment for AMLA’s due diligence standards: technical standards tracker.
• Articles 33 to 46 cover simplified due diligence and enhanced due diligence, including politically exposed persons (Articles 42 to 46).
• Articles 48 to 50 cover reliance on other obliged entities.

Beneficial ownership (Chapter IV)

Articles 51 to 55 set how to find the beneficial owner of a legal entity through ownership, control, or both. Articles 58 to 60 deal with express trusts and discretionary trusts. Articles 63 to 66 put duties on the entities and arrangements themselves.

Reporting and information (Chapters V to VII)

Article 69 requires reporting of suspicions. Article 73 prohibits tipping off. Article 75 allows regulated information-sharing partnerships: Article 75. Article 77 covers record retention.

Anonymous instruments (Chapter VIII)

Article 79 bans anonymous accounts and phases out bearer shares. Article 80 caps cash payments for goods and services at EUR 10,000, with room for stricter national limits.

Our take

Firms often prepare by reading Chapter III and stop there. We would not. Article 10, the business-wide risk assessment, sits upstream of everything: Article 20(2) tells you that the extent of your due diligence follows from it. Get the risk assessment wrong and the rest is built on sand.

What this means for you

If you are not sure which of these articles bite on your business, ask us. Use the enquiry form to schedule a no-obligation call and we will tell you where we would look first.

General information, not legal advice. For wording, rely on the Official Journal.