Public consultation by AMLA on the draft Guidelines on business-wide risk assessment
AI Analysis
AMLA has launched a public consultation on draft Guidelines for business-wide risk assessments (BWRA) under the new Anti-Money Laundering Regulation (EU 2024/1624), with submissions open until 15 July 2026. These guidelines establish minimum requirements for all obliged entities across financial and non-financial sectors to systematically identify and manage money laundering and terrorist financing risks inherent to their operations.
Key dates
- Later in 2026
- - Final adoption of guidelines and technical standards
- 16 April 2026
- - Consultation launched
- 20 May 2026, 10:00–12:00 CET
- - Public hearing on draft RTS on group-wide requirements
- 28 May 2026, 10:00–12:00 CET
- - Public hearing on draft Guidelines on business-wide risk assessment
- 15 July 2026 Deadline
- - Consultation deadline for submissions
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):
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
Compliance impact
Urgency: HIGH
Who is affected
Related regulations
References
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What the CSSF said
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