Art. 28 Feedback by FIU | Sixth anti-money laundering (AML 6) directive | AML

This article governs the feedback loop that FIUs must maintain with obliged entities following the submission of suspicious transaction reports, as required under Article 69 of Regulation (EU) 2024/1624.

Rather than being a passive recipient of reports, the FIU is positioned here as an active communicator, obliged to return structured feedback covering the quality of information, timeliness, description of suspicion, and documentation submitted.

The article also extends this feedback obligation to customs authorities and requires FIUs to report annually to AMLA on their feedback activities.

AMLA itself is tasked with issuing best practice recommendations to FIUs by 10 July 2028.

Important points:

FIUs are required to provide feedback to obliged entities on their suspicious transaction reporting at least once per year, and this feedback must also be made available to supervisors to support risk-based supervision.
The feedback obligation does not require a response to every individual report, and it must not jeopardise ongoing investigations, analytical work, or data protection and confidentiality requirements.
FIUs are required to report annually to AMLA on their feedback activities and provide statistics on suspicious transaction reports submitted by categories of obliged entities.

1. Member States shall ensure that FIUs provide obliged entities with feedback on the reporting of suspicions pursuant to Article 69 of Regulation (EU) 2024/1624. Such feedback shall cover at least the quality of the information provided, the timeliness of reporting, the description of the suspicion and the documentation provided at submission stage.
2. Feedback pursuant to this Article shall not be understood as encompassing each report submitted by obliged entities.
3. The FIU shall provide feedback at least once per year, whether provided to the individual obliged entity or to groups or categories of obliged entities, taking into consideration the overall number of suspicious transactions reported by the obliged entities.
4. Feedback shall also be made available to supervisors to allow them to perform risk-based supervision in accordance with Article 40.
5. FIUs shall report on an annual basis to AMLA on the provision of feedback to obliged entities pursuant to this Article, and shall provide statistics on the number of suspicious transaction reports submitted by the categories of obliged entities.
6. By 10 July 2028, AMLA shall issue recommendations to FIUs on best practices and approaches towards the provision of feedback, including on the type and frequency of feedback.
7. The obligation to provide feedback shall not jeopardise any ongoing analytical work carried out by the FIU or any investigation or administrative action subsequent to the dissemination by the FIU, and shall not affect the applicability of data protection and confidentiality requirements.
1. Member States shall ensure that FIUs provide customs authorities with feedback, at least on an annual basis, on the effectiveness of and follow-up to the information transmitted pursuant to Article 9 of Regulation (EU) 2018/1672.