Specifically, the European Commission asked us to advise it on a common ML/TF risk assessment methodology for AML/CFT supervisors in line with Article 31(2) of the AMLD6 and on the methodology AMLA will use to select institutions that will be directly supervised by it pursuant to Article 12(5) of the AMLA Regulation.

Our advice will also cover customer due diligence under Article 22(1) of the AMLR and the criteria that supervisors will use to determine pecuniary sanctions or administrative measures under Article 39(7) of the AMLD6.  In addition, the European Commission asked us to consider possible guidance on the base amounts for pecuniary sanctions under Article 39(8) of the AMLD6 and on the minimum requirements for group-wide policies under Article 13(3) of the AMLR.

We will consult on our draft response in Q1 2025 and revert to the European Commission by 31 October 2025.