AMLA ¦ AMLA Invites Stakeholders to Sectoral Roundtables on Simplified Customer Due Diligence

AMLA ¦ AMLA Invites Stakeholders to Sectoral Roundtables on Simplified Customer Due Diligence

AMLA opens sectoral roundtables on simplified customer due diligence

The Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) is inviting obliged entities, trade associations and other representative bodies from the financial and non-financial sectors to take part in sectoral roundtables on simplified customer due diligence (SDD). What participants contribute will feed into own-initiative Guidelines that AMLA is preparing under Article 54 of the AMLA Regulation, Regulation (EU) 2024/1620. Expressions of interest can be submitted until 18 October 2026 at 23:59 CEST.

Guidelines to make lower-risk treatment usable

Article 54 of the AMLA Regulation allows the Authority to issue guidelines and recommendations addressed, among others, to obliged entities, in order to ensure the common, uniform and consistent application of Union law. AMLA is using that power on its own initiative to address one of the least consistently applied parts of the AML/CFT framework: the treatment of customers and situations that present a lower degree of money laundering and terrorist financing risk.

Simplified measures have been permitted for years, yet many obliged entities rarely use them. Unclear conditions, divergent national practice and the fear of supervisory criticism have pushed firms toward collecting the same information from every customer, whatever the risk. That wastes compliance resources that should go to higher-risk relationships, and it can exclude customers who cannot produce the documents demanded of them.

The planned Guidelines are meant to support a harmonised, proportionate application of SDD across sectors. AMLA is explicit about the limits: the Guidelines will stay within the existing legal framework and will create no exemptions from the requirements of the Anti-Money Laundering Regulation (AMLR). Reduced measures will still have to rest on a documented assessment that the risk is low.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"Simplified due diligence is one of the most underused tools in the AML/CFT framework, mostly because firms cannot be sure a supervisor will accept it. Guidelines built on real, sector-specific scenarios could give compliance teams the confidence to scale down measures where the risk is low and spend their effort where it matters.

The deadline is short and the seats are limited, so associations and firms should decide quickly whether to apply. Those who bring concrete, anonymised cases with a clear risk rationale will have the best chance of seeing their situations reflected in the draft."

A forum for practical scenarios

The roundtables are designed as a structured exchange on concrete situations. Participants are expected to present anonymised examples of recurring cases that may warrant a simplified or proportionate approach, including how often they occur, and to explain how these cases are handled today under the existing CDD rules.

AMLA also wants views on how SDD can be applied proportionately in those situations, on the low risks associated with them and the measures needed to manage those risks, and on how simplified treatment can stay fully consistent with the AMLR. The evidence most likely to carry weight is a specific, well-documented scenario with a clear explanation of why its risk is low.

The roundtables are not a public consultation. They feed into the drafting of the Guidelines, and a formal public consultation on the draft text will follow later.

Who can apply

The call is addressed to European-level trade associations and representative bodies of obliged entities, to national associations where no relevant European body exists, to individual obliged entities with relevant operational or sectoral experience, and to other bodies representing categories of obliged entities. AMLA particularly encourages applications from the non-financial sector and from sectors that face specific difficulties in applying CDD requirements.

Nominated representatives should have practical expertise and enough seniority to speak for their organisation. Applications are made through an EU Survey form, which asks for concise information on the organisation, its sectoral and geographic coverage, its expertise and the practical situations it could contribute.

Selection and limits on participation

AMLA will decide the number, scope and composition of the roundtables once it has reviewed the applications. Each roundtable is capped at 25 participants. Selection will take into account representativeness at EU level, coverage of different business models, sizes and structures, geographic balance, the inclusion of less mature or previously underrepresented sectors, and the seniority and expertise of the nominees.

AMLA may also invite national supervisors as subject-matter experts or reach out directly to fill gaps in coverage. Submitting an expression of interest creates no right to participate and no privileged access to AMLA or to the drafting process. All applicants will be informed of the outcome by 30 October 2026.

Practical arrangements

The roundtables will be held in person in Frankfurt am Main between 9 November and 2 December 2026. Each is expected to last between half a day and a full day. The working language is English, with no interpretation, and all written contributions must be in English. Selected participants will be asked to submit short written input in advance, and they will bear their own travel costs.

Applicants must not include customer-level information, personal data on customers, suspicious transaction information, legally privileged material, trade secrets or other confidential case information in their expression of interest. Any examples discussed later must be properly anonymised. Questions about the call can be sent to sdd-roundtables@amla.europa.eu.

Why participation is worth considering

For sectors with large volumes of low-value, low-risk customers, such as retail payments, e-money, certain insurance products, collective investment schemes distributed through regulated intermediaries, and many non-financial professions, the Guidelines could determine how much of their onboarding effort is actually required. Firms and associations that bring well-documented scenarios can influence how those situations end up being described.

In Luxembourg, the investment fund sector has an obvious stake. Layered distribution chains and intermediated investor relationships raise recurring questions about proportionate CDD, and those scenarios belong in the discussion. With a deadline of 18 October 2026, any association or firm intending to apply should identify its candidate scenarios and its representative now.

The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
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Dive deeper
  • AMLA ¦ AMLA invites stakeholders to sectoral roundtables on simplified customer due diligence ¦ Link
  • AMLA ¦ Expression of interest form (EU Survey, deadline 18 October 2026) ¦ Link
Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.