Article 28 Information on the reasons for the intended or performed transactions and their consistency with the business relationship

This is a draft act

This text has been parsed from the AMLA consultation paper draft as published on 9 February 2026. While we run a suite of validations, the automated parsing can result in errors. Also, before it is finally adopted by the Commission, its wording, numbering and references may change, and entire articles might be removed or added.

Summary What does Article 28 of the RTS on customer due diligence say?

This article supports the enhanced due diligence framework established under Article 34(4)(d) of Regulation (EU) 2024/1624, specifically addressing what obliged entities must gather when scrutinising the reasons behind transactions.

The core purpose is to ensure that transactions make sense in the context of the broader business relationship — that they are credible, consistent with what the obliged entity knows about the customer, and free from unexplained higher-risk indicators.

The article gives obliged entities some flexibility in how they satisfy this requirement, allowing them to pursue one or more lines of inquiry depending on what is most relevant to the situation at hand.

Important points:

Obtain additional information on the reasons for intended or performed transactions to assess their consistency with the business relationship.
Pay particular attention to the overall pattern of transactions across the business relationship, especially where economic activities involve higher ML/TF risk assets.
Where higher risks have already been identified regarding parties involved in a transaction, including intermediaries, gather information to clarify those risks and their connection to the customer.

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

For the purposes of Article 34(4), point (d), of Regulation (EU) 2024/1624, obliged entities shall obtain one or more of the following information on the reasons for the intended or performed transactions and their consistency with the business relationship, on which basis they can assess:
1. the extent to which the reason provided for the transaction is credible and in line with the institution’s knowledge of the customer; or
2. the consistency of the overall transactions performed during the business relationship with the activities carried out and the customer’s turnover, especially in the case of economic activities characterised by the use of assets representing higher ML/TF risks; or
3. information to clarify any higher risks the obliged entity may have identified in respect of the parties involved in the transaction, including any intermediaries, and their relationship with the customer.

Table of contents

Springlex and this text is meant purely as a documentation tool and has no legal effect. No liability is assumed for its content. The authentic version of this act is the one published in the Official Journal of the European Union.