The European Anti-Money Laundering Authority (AMLA) is progressing with the implementation of the EU’s revised anti-money laundering and counter-terrorist financing (AML/CFT) framework.
Recent developments include three finalised sets of draft Regulatory Technical Standards (RTS), preparations for a central European supervisory database and further work on simplified customer due diligence.
For insurance intermediaries subject to AML/CFT obligations, these developments provide a clearer indication of how the future European requirements may affect customer identification, screening, ongoing monitoring and internal compliance procedures.
Three sets of technical standards: what do they mean in practice?
On 1 October 2026, AMLA announced the completion of three sets of draft RTS, submitted to the European Commission for adoption.
1. Customer due diligence: more detailed requirements, with room for proportionality
The first set of standards specifies how obliged entities must identify and verify customers and beneficial owners, establish the purpose and intended nature of business relationships, and apply screening and due diligence measures.
Several provisions are particularly relevant in practice:
- Customer identification: the draft introduces flexibility regarding identification details, including place of birth and nationality, to accommodate differences between identity documents and electronic identification systems.
- Remote identification: electronic identification and remote verification methods are addressed, with safeguards concerning the reliability, security and confidentiality of the verification process.
- PEP and sanctions screening: automated tools are not necessarily required. Manual checks or a combination of approaches may be used, provided screening remains effective and proportionate to the intermediary’s activities, risks, complexity and size.
- Beneficial ownership: certain requirements concerning ownership and control structures have been simplified, while the obligation to understand and verify relevant beneficial ownership information remains.
- Existing customers: information relating to established business relationships will need to be aligned with the new requirements on a risk-sensitive basis, within the applicable updating periods. This does not imply an automatic requirement to repeat the full identification process for every client.
These provisions are particularly relevant to firms reviewing their customer onboarding procedures, compliance tools and management of existing client portfolios.
2. Business relationships and occasional transactions: clarifying when obligations apply
The second set of RTS establishes criteria for distinguishing ongoing business relationships from occasional transactions and for identifying linked transactions.
This distinction is important because ongoing business relationships require customer due diligence and continuing monitoring, whereas the treatment of occasional transactions depends on the applicable thresholds and other risk-related circumstances.
For insurance intermediaries, the assessment will take account of factors such as the expected duration of the relationship and the anticipated repetition of services.
The draft also clarifies that identifying linked transactions should rely on information already available or reasonably accessible to the obliged entity, rather than requiring disproportionate additional data collection.
AMLA has not proposed further reductions to the customer due diligence thresholds for occasional transactions beyond those already provided for in the AML Regulation.
The approach is largely principles-based, allowing intermediaries to assess the nature of their customer relationships in light of their actual activities.
3. Group-wide arrangements: consistent controls and information sharing
The third set of RTS concerns AML/CFT arrangements within groups, including governance, risk management, internal controls and information sharing between group entities.
It also addresses situations involving subsidiaries or branches in third countries, particularly where local legislation restricts the implementation of group-wide AML/CFT requirements.
These provisions are primarily relevant to intermediary groups operating through multiple legal entities or across borders.
Proportionality remains a central consideration
BIPAR participated in the consultations on the three draft standards, together with the input from member associations, including Becobra, advocating for effective but proportionate requirements that reflect the characteristics of insurance intermediation.
Several concerns raised during the consultations have been reflected in the final drafts, notably greater flexibility in identification requirements, simplified provisions concerning beneficial ownership and a technology-neutral approach to screening.
The recognition that effective screening does not necessarily require automated solutions is particularly relevant for intermediaries with different business models, customer volumes and risk profiles.
Nevertheless, proportionality does not remove the obligation to demonstrate that the measures applied are appropriate and effective.
Simplified customer due diligence: Becobra participates in European discussions
Alongside the technical standards, AMLA is developing guidelines on the application of simplified customer due diligence (SDD) in lower-risk situations.
AMLA has indicated that the draft RTS themselves offer limited scope for further general simplification without going beyond the provisions of the AML Regulation. Additional guidance is therefore important to clarify how simplified measures can be applied in practice.
Becobra is bringing forward members’ expertise in participation to the sectoral roundtable on simplified customer due diligence, alongside other representatives coordinated through BIPAR.
The discussions focus on identifying genuinely lower-risk situations, examining existing practices and determining which simplified measures and safeguards are appropriate.
For insurance intermediaries, this is particularly relevant to products and relationships presenting limited money laundering or terrorist financing risks.
Becobra’s objective is to contribute practical sector experience and support an approach in which due diligence requirements reflect actual risks rather than imposing unnecessarily uniform procedures across different products and business models.
The discussions will inform AMLA’s future guidelines.
A central European AML/CFT supervisory database
AMLA is also developing a central European database to improve information sharing between supervisory authorities and support more consistent, risk-based supervision.
The database will contain information concerning obliged entities, including AML/CFT risk profiles, supervisory measures, sanctions, authorisations and relevant fit-and-proper assessments.
The related draft RTS were the subject of a public consultation and hearing.
AMLA indicates that the proposed database will not create new direct reporting obligations for intermediaries. Information will be transmitted by supervisory authorities, primarily using data already held or otherwise required under the applicable framework.
Nevertheless, the initiative represents a step towards more structured European supervisory information sharing, making data quality, confidentiality and proportionate supervisory practices important considerations.
Preparing for the new framework: European developments and Belgian sector arrangements
The EU Anti-Money Laundering Regulation will generally apply from 10 July 2027.
The three finalised draft RTS still require adoption by the European Commission and publication in the Official Journal. As currently proposed, they would apply six months after their entry into force.
In the meantime, existing Belgian AML/CFT obligations and FSMA supervisory requirements remain applicable.
At Belgian level, Becobra is working with the other sectoral associations on a revision of the existing sectoral AML/CFT agreement, taking account of regulatory developments and practical experience within the insurance sector.
This work is distinct from AMLA’s European rulemaking but shares the objective of ensuring that AML/CFT measures are effective, coherent and workable in practice.
Becobra will continue to contribute to the development of proportionate AML/CFT requirements at European and Belgian level, with particular attention to legal certainty, operational feasibility and the specific characteristics of insurance intermediation.
