AMLA draft Guidance on Ongoing Monitoring
This is one of the early outputs from AMLA under the new AML framework, aiming to provide further clarity on the application of ongoing monitoring requirements under the AML Regulation (AMLR).
• Focus on operational clarity (rather than purely new concepts)
The draft Guidelines seek to clarify how existing obligations on ongoing monitoring should be applied in practice. While not introducing fundamentally new requirements, they contribute to a more structured articulation of supervisory expectations.
• Reinforcement of the risk-based approach
The Guidelines reiterate that ongoing monitoring should be risk-based and proportionate. This is not new, but it signals that competent authorities are likely to place greater emphasis on how subject persons evidence and justify their monitoring frameworks in practice.
• Greater emphasis on maintaining an up-to-date customer understanding
Beyond transaction monitoring, the draft highlights the importance of ensuring that customer information remains current and consistent over time, including through ongoing reassessment where relevant. This reflects a continued shift toward more dynamic customer risk profiling.
• Applicability across a wider range of obliged entities
The Guidelines are intended to apply across all obliged entities under the AMLR, including sectors more recently brought into scope. This supports AMLA’s objective of promoting greater supervisory convergence across the EU rather than introducing sector-specific expectations.
For further information, refer to AMLA’s webiste: https://www.amla.europa.eu/amla-consults-draft-guidelines-ongoing-monitoring-business-relationships_en
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