Art. 69 Reporting of suspicions | Anti-money laundering regulation (AMLR) | AML

This is a core operational article that sets out the suspicious transaction reporting obligations of obliged entities toward their Financial Intelligence Unit (FIU).

It covers the full reporting lifecycle: the duty to report on own initiative, the obligation to respond to FIU requests, the standard for forming a suspicion, timelines for responding, and protections for those carrying out the reporting tasks.

The article also addresses how reporting works in the specific context of a partnership for information sharing, where multiple obliged entities may coordinate to submit a single report.

It connects directly to Article 11, which establishes the compliance officer role responsible for transmitting these reports.

Important points:

Report to the FIU on your own initiative whenever you know, suspect, or have reasonable grounds to suspect that funds or activities are linked to criminal activity or terrorist financing, regardless of the amount involved — this includes attempted transactions and cases where customer due diligence could not be completed.
Respond to FIU requests for information within 5 working days, though the FIU can shorten this deadline in urgent cases or extend it where justified.
Ensure that the compliance officer and all staff involved in reporting tasks are protected against retaliation, discrimination, and any other unfair treatment for carrying out those tasks.

1. Obliged entities, and, where applicable, their directors and employees, shall cooperate fully with the FIU by promptly:
  1. reporting to the FIU, on their own initiative, where the obliged entity knows, suspects or has reasonable grounds to suspect that funds or activities, regardless of the amount involved, are the proceeds of criminal activity or are related to terrorist financing or criminal activity and by responding to requests by the FIU for additional information in such cases;
  2. providing the FIU, at its request, with all necessary information, including information on transaction records, within the deadlines imposed.
2. All suspicious transactions, including attempted transactions and suspicions arising from the inability to conduct customer due diligence shall be reported in accordance with the first subparagraph.
3. For the purposes of the first subparagraph, obliged entities shall reply to requests for information by the FIU within 5 working days. In justified and urgent cases, FIUs may shorten that deadline, including to less than 24 hours.
4. By way of derogation from the third subparagraph, the FIU may extend the deadline for a response beyond the 5 working days where it considers it justified and provided that the extension does not undermine the FIU’s analysis.
1. For the purposes of paragraph 1, obliged entities shall assess transactions or activities carried out by their customers on the basis of and against any relevant fact and information known to them or which they are in possession of. Where necessary, obliged entities shall prioritise their assessment taking into consideration the urgency of the transaction or activity and the risks affecting the Member State in which they are established.
2. A suspicion pursuant to paragraph 1, point (a), shall be based on the characteristics of the customer and their counterparts, the size and nature of the transaction or activity or the methods and patterns thereof, the link between several transactions or activities, the origin, destination or use of funds, or any other circumstance known to the obliged entity, including the consistency of the transaction or activity with the information obtained pursuant to Chapter III including the risk profile of the client.
1. By 10 July 2026, AMLA shall develop draft implementing technical standards and submit them to the Commission for adoption. Those draft implementing technical standards shall specify the format to be used for the reporting of suspicions pursuant to paragraph 1, point (a), and for the provision of transaction records pursuant to paragraph 1, point (b).
1. Power is conferred on the Commission to adopt the implementing technical standards referred to in paragraph 3 of this Article in accordance with Article 53 of Regulation (EU) 2024/1620.
1. By 10 July 2027, AMLA shall issue guidelines on indicators of suspicious activity or behaviours. Those guidelines shall be periodically updated.
1. The compliance officer appointed in accordance with Article 11(2) shall transmit the information referred to in paragraph 1 of this Article to the FIU of the Member State in whose territory the obliged entity transmitting the information is established.
1. Obliged entities shall ensure that the compliance officer appointed in accordance with Article 11(2), as well as any employee or person in a comparable position, including agents and distributors, involved in the performance of the tasks covered by this Article are protected against retaliation, discrimination and any other unfair treatment for carrying out those tasks.
2. This paragraph shall not affect the protection that the persons referred to in the first subparagraph may be entitled to under Directive (EU) 2019/1937.
1. Where the activities of a partnership for information sharing result in the knowledge, suspicion or reasonable grounds to suspect that funds, regardless of the amount involved, are the proceeds of criminal activity or are related to terrorist financing, obliged entities which identified suspicions in relation to the activities of their customers may designate one among them which shall be tasked with the submission of a report to the FIU pursuant to paragraph 1, point (a). Such submission shall include at least the name and contact details of all the obliged entities that participated in the activities giving rise to the report.
2. Where the obliged entities referred to in the first subparagraph are established in several Member States, the information shall be reported to each relevant FIU. To that end, obliged entities shall ensure that the report is submitted by an obliged entity within the territory of the Member States where the FIU is located.
3. Where the obliged entities decide not to avail themselves of the possibility to submit a single report with the FIU pursuant to the first subparagraph, they shall include a reference in their reports to the fact that the suspicion is the result of the activities of a partnership for information sharing.
1. The obliged entities referred to in paragraph 8 of this Article shall retain a copy of any reports submitted pursuant to that paragraph in accordance with Article 77.