Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 25 JUNE 2026

Customer Due Diligence Measures – Key Changes You Need To Know

CMS Luxembourg
Explore more from CMS Luxembourg

The Anti-Money Laundering Regulation introduces significant changes to Customer Due Diligence requirements, expanding trigger events and deepening information obligations. Organizations must understand these new compliance measures, including lower transaction thresholds, enhanced sanctions screening, and stricter reporting requirements before the July 2027 implementation deadline.

LuxembourgGovernment, Public Sector
Aurélia Viémont
Aurélia Viémont
Mélanie Poirrier
Mélanie Poirrier
Delia Nesbitt
Delia Nesbitt
Author LinkedIn connections

The Anti-Money Laundering Regulation (AMLR) introduces several important changes to Customer Due Diligence (CDD) requirements. These updates expand the scope of trigger events, deepen the level of information required, and reinforce compliance obligations for obliged entities.

New trigger events for CDD measures

Under the AMLR, the situations triggering CDD measures have been broadened. These include, among others:

  • Any occasional transaction of at least EUR 10,000, compared to EUR 15,000 under the current regime.
  • Participation in the creation of legal entities, including:
    • the setting up of a legal arrangement; or
    • for auditors and legal professionals, participation in the transfer of ownership of a legal entity, regardless of the transaction value.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

AMLA Finalises Three Sets Of Regulatory Technical Standards

The Anti-Money Laundering Authority has finalized three sets of Regulatory Technical Standards that will establish a unified framework for obliged entities across the European Union to combat money laundering and terrorist financing. These standards address customer due diligence requirements, transaction identification criteria, and group-wide compliance measures, marking a significant step toward harmonized AML/CFT enforcement throughout the EU.
European UnionGovernment, Public Sector
Ganado Advocates
Ganado Advocates
Article

New Limit To Large Cash Payments And Prohibition Of Anonymous Instruments

The Anti-Money Laundering Regulation introduces sweeping changes to EU financial compliance, establishing a EUR 10,000 cap on cash transactions, prohibiting anonymous financial instruments, and mandating the conversion of bearer shares. These measures fundamentally reshape how businesses handle large payments and corporate ownership structures, with strict deadlines and automatic penalties for non-compliance.
LuxembourgGovernment, Public Sector
CMS Luxembourg
CMS Luxembourg
Article

AML/CTF Playbook: EU Edition #3: Mapping The Expansion Of EU Obliged Entities

The European Union's newly adopted anti-money laundering and counter-terrorist financing package represents a significant evolution in financial crime prevention, introducing a harmonised rulebook that expands the range of entities required to comply with AML/CTF obligations. This comprehensive analysis examines how the Package transforms the regulatory landscape for obliged entities across EU member states, comparing the new requirements against both the previous EU directive framework and existing domesti
European UnionGovernment, Public Sector
A&O Shearman
A&O Shearman