EBA
European Banking Authority
Group-wide AML — what a parent must push down
Group-wide AML under AMLR Article 16: the group risk assessment, group policies and information sharing, and third-country branches under Article 17.
When due diligence fails — refrain, terminate, consider
AMLR Article 21: what to do when customer due diligence cannot be completed, the three required steps, and the limits on terminating…
Simplified due diligence — five measures, one 60-day cap
Simplified due diligence under AMLR Article 33: the five measures, the 60-day cap, pre-verification limits, and when simplified treatment must stop.
Timing of verification — AMLR Article 23 explained
AMLR Article 23 timing of verification: verify-before rule, during-establishment and account-opening derogations, the 60-day SDD cap, proof of registration.
Register discrepancies — the 14-day reporting duty
Beneficial ownership register discrepancies under AMLR Article 24: the 14-calendar-day deadline, what to send, and the two cases you need not report.
Reporting suspicions — the AMLR duty and its clocks
Reporting suspicions under AMLR Article 69: the knowledge and suspicion test, attempted transactions, and the five-working-day deadline for FIU requests.
AML training — the duty that reaches your agents
AML training under AMLR Article 12: who must be trained including agents and distributors, what the programme must achieve, and the documentation…
Policies, procedures and controls — two approval levels
AMLR Article 9: what internal policies, procedures and controls must cover, the two approval altitudes, and why one omnibus AML manual maps…
Business-wide risk assessment — the six mandatory inputs
The AMLR business-wide risk assessment under Article 10: the six inputs you must take into account, the pre-launch duty, and who draws…
Crypto laundering typologies — what the AMLR names
Crypto laundering typologies in EU law: self-hosted address transfers under AMLR Article 40, nested exchanges, shell institutions and the mitigating measures.