2026-03-20

AMLA Risk Model Test Request Launched

The Authority for the Financial Markets (AFM) and the European Anti-Money Laundering Authority (AMLA) have launched a mandatory data collection exercise requiring selected financial companies to submit information for testing AMLA’s new risk assessment model. The AFM will host a second series of sector-wide roundtables in late 2026 to discuss the upcoming July 2027 implementation of revised EU anti-money laundering and counter-terrorist financing rules, alongside the publication of further national secondary legislation. Concurrently, AMLA will conduct public hearings on 24 March 2026 regarding draft regulatory technical standards for customer due diligence, business relationships, and administrative enforcement measures.

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20/03/26

The European Anti-Money Laundering Authority AMLA has published the test request on its website. Companies subject to the supervision of the Authority for the Financial Markets (AFM) are also participating in this test request. The test request is intended to help AMLA develop a model that identifies risks for financial companies in the areas of money laundering and terrorist financing based on data. Filling out the test request is mandatory.

In brief

Final reporting package for test request

Follow-up sector-wide EU AML-CFT roundtables at the AFM

Public hearings on draft secondary legislation

The companies selected for the test request have previously received a notification from us, and we have also published a report on this topic on our website. The test request is taking place in all European member states and across various financial sectors. The broader sector-wide request will follow in 2027.

Final reporting package for test request This week, the European authority AMLA published the definitive 'reporting package' for the test request. This is partly based on feedback previously requested from the sector regarding the draft test request. Even for financial companies that were not selected, it may be interesting to review the reporting package from the test request, as it provides an overview of the broader request scheduled for next year.

Follow-up sector-wide EU AML-CFT roundtables at the AFM By the end of 2026, we intend to hold a second series of roundtable discussions with institutions subject to the AFM's anti-money laundering and counter-terrorist financing supervision, regarding the new legislation that will largely enter into force on 10 July 2027. Since November, we have already held these discussions with various sectors. These sessions have yielded valuable insights into expectations, questions, and bottlenecks regarding the transition to the new European framework, and participants found the discussions positive and constructive. The second round will focus primarily on the publication of further secondary legislation and adjustments to the national framework.

Public hearings on draft secondary legislation AMLA is also informing the sector itself. On 24 March 2026, it will organize two 'public hearings' on the:

concept regulatory technical standards (RTS) on customer due diligence (CDD)

concept-RTS on business relationships, occasional transactions, and linked transactions

concept-RTS on administrative enforcement measures

The latter two were also recently consulted with stakeholders. The secondary legislation will be codified in regulatory technical standards. The draft RTSs are relevant for the specific implementation of the initiation of client due diligence and the manner in which client due diligence must be carried out.

More information about the public hearings can be found on AMLA's website.

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Advisors, intermediaries & authorized representatives

Investment institutions

Investment companies

Crypto service providers

Preventing money laundering and terrorist financing - compliance with the Sanctions Act

More information

AFM sends test request to European anti-money laundering authority for risk model data collection

AMLA launches data collection exercise to test risk assessment models

Roundtable discussions on new European anti-money laundering and counter-terrorist financing rules begin

AMLA launches consultation on secondary legislation and data collection

AMLA to Hold Public Hearing on Two Draft RTS

Topic page preventing money laundering, terrorist financing - compliance with the Sanctions Act

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