AMLA's New AML Standards: What the 'Principles-Based' Label Really Means for Your Firm

Alejandro Martínez · 2026-10-15

On October 1, 2026, the Anti-Money Laundering Authority (AMLA) finalized three regulatory technical standards under the Anti-Money Laundering Regulation (Regulation (EU) 2024/1624). These standards cover customer due diligence, the line between a business relationship and an occasional transaction, and group-wide arrangements. They apply to both financial and non-financial obliged entities. AMLA emphasizes that the standards are principles-based and don't add new obligations beyond the AMLR itself. But let's not gloss over that "principles-based" label. It's more than a throwaway phrase—it changes how firms need to think about compliance. ### Why 'Principles-Based' Is a Big Deal In a rules-based system, you can point to a checklist and say, "I did X, Y, and Z." In a principles-based system, you have to show that your approach actually achieves the goal. The burden of proof shifts onto you. Supervisors won't just tick boxes; they'll ask, "Why did you design it this way?" and "How do you know it works?" That means your policies and procedures need to be defensible on substance, not just form. You'll need to document your reasoning and be ready to explain your choices. > "Principles-based regulation doesn't mean less regulation—it means more judgment, and more accountability." – Roberto Buttigieg, AML & Risk Advisor ### What the Three Standards Cover - **Customer due diligence (CDD):** The standard clarifies how to apply CDD measures proportionately, based on risk. It's not one-size-fits-all; you'll need to tailor your approach. - **Business relationship vs. occasional transaction:** This distinction matters because it determines when enhanced measures kick in. The standard provides criteria to help you classify transactions correctly. - **Group-wide arrangements:** For groups operating across borders, the standard sets expectations for consistent AML/CFT policies and information sharing. ### Practical Implications for Compliance Teams So, what does this mean for your day-to-day? Here are a few things to keep in mind: - **Review your risk assessments:** Make sure they're not just a paper exercise. They should drive your CDD approach. - **Document your rationale:** When you decide a transaction is occasional, write down why. When you apply simplified measures, record the reasoning. - **Train your staff:** Frontline teams need to understand the principles, not just the rules. They should know how to exercise judgment. - **Engage with supervisors:** Don't wait for an exam to discuss your approach. Proactive dialogue can help align expectations. ### The Bottom Line AMLA's new standards are a nudge—or maybe a shove—toward a more thoughtful, risk-based approach to AML. The principles-based label isn't an escape hatch; it's a call to action. Firms that invest in understanding the "why" behind their controls will be better positioned to meet supervisory expectations. And remember, these standards apply to both financial and non-financial obliged entities. So whether you're a bank, a law firm, or a real estate agent, the ball is in your court.