Introduction
On 3 June 2026, the Authority for Anti-Money Laundering and Countering the Financing of Terrorism ("AMLA") published a Consultation Paper on Draft guidelines on the ongoing monitoring of business relationships under Article 26(5) of Regulation (EU) 2024/1624 (“AMLR”)(“Draft Guidelines”).
Background
Article 26 of the AMLR requires obliged entities to conduct ongoing monitoring of business relationships, including periodic customer due diligence reviews and transaction/activity monitoring to detect potentially suspicious behaviour. Paragraph 5 of this Article provides that AMLA will issue guidelines on the expected manner of complying with this obligation. Please see below the general review of the proposed content of the Draft Guidelines.