Consultation by AMLA on the draft RTS on criteria for identifying business relationships, occasional and linked transactions and lower thresholds

This draft RTS establishes criteria for identifying business relationships, occasional transactions, and linked transactions. Distinguishing between business relationships and occasional transactions is a fundamental step in applying the AML/CFT framework. For business relationships, obliged entities must always perform customer due diligence (CDD). For occasional transactions, CDD is required only when the transaction value exceeds certain thresholds. Identifying linked transactions is equally important, as it prevents criminals from circumventing these thresholds by structuring their activities across multiple smaller transactions.

The criteria in this draft RTS apply to all obliged entities across both the financial and non-financial sectors. While some criteria are universal, others are tailored to specific categories of obliged entities.