Article 29 Screening of customers and beneficial owners


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 29 of the RTS on customer due diligence say?

This concise but important article places a clear obligation on obliged entities to check whether their customers, beneficial owners, and those who control or hold ownership over customers are subject to targeted financial sanctions.

It also extends this obligation in a specific scenario: where there is a suspicion that someone may be trying to circumvent or evade those sanctions, obliged entities must also check whether the person acting on behalf of the customer is themselves a sanctioned party.

Article 29 works closely with Article 30, which sets out the practical screening tools and processes obliged entities must use to fulfil this obligation.

Important points:

  • Establish whether your customers, their beneficial owners, and relevant controlling persons are subject to targeted financial sanctions.
  • Where circumvention or evasion of sanctions is suspected, extend that check to any person acting on behalf of the customer.
  • Targeted financial sanctions cover both asset freezing and prohibitions on making funds or assets available to designated persons and entities.

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

  1. Obliged entities shall establish whether their customers, the beneficial owners and the entities or persons which control or meet the ownership conditions stipulated in Article 20(1), point (d), of Regulation (EU) 2024/1624 are subject to targeted financial sanctions. Where there is a suspicion of circumvention or evasion of targeted financial sanctions, obliged entities shall also establish whether the person acting on behalf of the customer is subject to targeted financial sanctions.

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

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