Public consultation by AMLA on the draft Guidelines on business-wide risk assessment

What Changed

• The draft Guidelines introduce four minimum requirements for conducting adequate business-wide risk assessments applicable to all obliged entities. The framework mandates that entities:
• Identify risk exposure across their business model, customers, products, services, transactions, delivery channels, and geographical exposure
• Maintain consolidated risk views across group structures, eliminating silos between branches and subsidiaries
• Utilize internal and external data sources to build comprehensive risk landscapes, including monitoring customer behavior changes and tracking international typologies
• Apply proportionality based on entity size, business model, and risk profile, while ensuring consistent application of policies across the organization The guidelines specifically address evaluation of high-risk jurisdictions and new technologies us

Suggested Considerations

• *Immediate (by 15 July 2026):
• Review draft Guidelines and assess alignment with current BWRA practices
• Identify gaps between existing risk assessment frameworks and proposed minimum requirements
• Prepare formal consultation responses, particularly if your organization operates in non-financial sectors
• Register for relevant public hearings (28 May for BWRA Guidelines; 20 May for group-wide RTS) to engage directly with AMLA
• *Medium-term (post-consultation):

Key Dates

Who is Affected