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ARTICLE · 25 JUNE 2026

Risk-based Approach : Key Updates

CMS Luxembourg
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The Anti-Money Laundering Regulation (AMLR) introduces a more structured framework for risk assessment while maintaining the Risk-Based Approach at its core. Enhanced Due Diligence requirements now extend to high-net-worth individuals and residence-by-investment schemes, while Simplified Due Diligence faces stricter conditions. The regulation provides EU-wide clarity on politically exposed persons (PEPs) and establishes harmonised risk factors across member states.

LuxembourgCorporate/Commercial Law
Aurélia Viémont
Aurélia Viémont
Mélanie Poirrier
Mélanie Poirrier
Delia Nesbitt
Delia Nesbitt
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Under the AMLR, the fundamental principle remains unchanged: the Risk-Based Approach (RBA) continues to sit at the core of the AML-CTF framework.

The objective is clear. AML-CTF measures must be proportionate and tailored to the specific risks of money laundering and terrorist financing identified in each situation.

Risk assessment under the AMLR: what must be considered

The AMLR introduces a more structured framework for risk assessment, while maintaining continuity in substance.

Harmonised risk factors

Risk factors are now formally harmonised and listed in:

  • Annex II (lower risk), and
  • Annex III (higher risk) of the AMLR.

No change in substance

Despite this formalisation, there is no substantive change in how risks are assessed. Risk factors continue to relate to:

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