Source: OJ L, 2024/1624, 19.6.2024

Current language: EN

Article 3 Obliged entities


Summary What does Article 3 of the Anti-money laundering regulation (AMLR) say?

This is a foundational scoping article that defines who qualifies as an "obliged entity" under the regulation — in other words, who is bound by its AML/CFT requirements.

It covers two broad categories: financial sector entities (credit institutions and financial institutions, including crypto-asset service providers) and a wide range of non-financial professionals and businesses.

The non-financial category is notably broad, stretching from lawyers, accountants and notaries, through real estate agents, gambling service providers and dealers in precious metals, to crowdfunding intermediaries, investment migration operators, and — notably new additions — football agents and professional football clubs in respect of certain transactions.

This article is the gateway to the rest of the regulation; if an entity falls within its scope, all subsequent obligations apply to it.

Important points:

  • Determine whether your organisation falls within the list of obliged entities, as this article triggers all compliance obligations under the regulation.
  • The scope extends well beyond traditional financial institutions to include a wide range of non-financial professionals and businesses acting in the exercise of their professional activities.
  • Football agents and professional football clubs are explicitly included as obliged entities, though only in relation to specific transaction types such as investor dealings, sponsorship, and player transfers.

Springlex's summary of the article, a reading aid, not a substitute for the legal text.

The following entities are to be considered obliged entities for the purposes of this Regulation:

  1. credit institutions;

  2. financial institutions;

  3. the following natural or legal persons acting in the exercise of their professional activities:

    1. auditors, external accountants and tax advisors, and any other natural or legal person including independent legal professionals such as lawyers, that undertakes to provide, directly or by means of other persons to which that other person is related, material aid, assistance or advice on tax matters as principal business or professional activity;

    2. notaries, lawyers and other independent legal professionals, where they participate, whether by acting on behalf of and for their client in any financial or real estate transaction, or by assisting in the planning or carrying out of transactions for their client concerning any of the following:

      1. buying and selling of real property or business entities;

      2. managing of client money, securities or other assets, including crypto-assets;

      3. opening or management of bank, savings, securities or crypto-assets accounts;

      4. organisation of contributions necessary for the creation, operation or management of companies;

      5. creation, setting up, operation or management of trusts, companies, foundations, or similar structures;

    3. trust or company service providers;

    4. estate agents and other real estate professionals to the extent they act as intermediaries in real estate transactions, including in relation to the letting of immovable property for transactions for which the monthly rent amounts to at least EUR 10 000 or the equivalent in national currency, irrespective of the means of payment;

    5. persons trading, as a regular or principal professional activity, in precious metals and stones;

    6. persons trading, as a regular or principal professional activity, in high-value goods;

    7. providers of gambling services;

    8. crowdfunding service providers and crowdfunding intermediaries;

    9. persons trading or acting as intermediaries in the trade of cultural goods, including when this is carried out by art galleries and auction houses, where the value of the transaction or linked transactions amounts to at least EUR 10 000 or the equivalent in national currency;

    10. persons storing, trading or acting as intermediaries in the trade of cultural goods and high-value goods, when this is carried out within free zones and customs warehouses, where the value of the transaction or linked transactions amounts to at least EUR 10 000 or the equivalent in national currency;

    11. credit intermediaries for mortgage and consumer credits, other than credit institutions and financial institutions, with the exception of the credit intermediaries carrying out activities under the responsibility of one or more creditors or credit intermediaries;

    12. investment migration operators permitted to represent or offer intermediation services to third-country nationals seeking to obtain residence rights in a Member State in exchange for any kind of investment, including capital transfers, purchase or renting of property, investment in government bonds, investment in corporate entities, donation or endowment of an activity to the public good and contributions to the state budget;

    13. non-financial mixed activity holding companies;

    14. football agents;

    15. professional football clubs in respect of the following transactions:

      1. transactions with an investor;

      2. transactions with a sponsor;

      3. transactions with football agents or other intermediaries;

      4. transactions for the purpose of a football player’s transfer.

We're continuously improving our platform to serve you better.

Your feedback matters! Let us know how we can improve.

Found a bug?

Springflod is a Swedish boutique consultancy firm specialising in cyber security within the financial services sector.

We offer professional services concerning information security governance, risk and compliance.

Crafted with ❤️ by Springflod