Source: AMLA final report draft
- Anti-money laundering
AMLR supplemental acts
- RTS on customer due diligence
Article 25 Screening requirements
This is a draft act
This text has been parsed from the AMLA final report draft as published on 30 September 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.
Earlier drafts: AMLA consultation paper draft (9 February 2026)
Obliged entities shall establish whether their customers, the beneficial owners and the entities or persons that 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.
For the purposes of paragraph 1, obliged entities shall:
screen, through automated screening tools or solutions, manual checks or a combination thereof, at least the following information on customers, beneficial owners and the entities or persons that control or meet the ownership conditions in relation to such customers:
in the case of a natural person, all names, including first name(s) (given name(s)) and surname(s) (family name(s)), in their original alphabet and/or transliterated into the Latin alphabet;
in the case of a legal person, the legal name of the legal person, and, where applicable, trade names where they differ from the legal name in the original alphabet and/or transliterated into the Latin alphabet;
where available, any other names, aliases and digital wallet addresses, and where included in the lists of targeted financial sanctions.
Obliged entities shall determine whether to use automated screening tools, manual checks or a combination thereof having regard to the nature of the obliged entity's business, including its risks and complexity, and the size of the obliged entity, ensuring that the screening arrangements are effective;
in the case that any of the persons specified in Article 20(1), point (d) of Regulation (EU) 2024/1624 are identified as subject to targeted financial sanctions, the information referred to in point (a) shall be checked against all available due diligence information related to that person. In the case of doubt, the obliged entity shall refer to all other sources available to them, including public sources of information, such as registers of owned and controlled entities and central registers;
screen their customers, beneficial owners and entities or persons that control or meet the ownership conditions under Article 20(1), point (d), of Regulation (EU) 2024/1624, at least under the following circumstances:
when entering into a business relationship or performing an occasional transaction;
when there is a change in any of the existing targeted financial sanctions or in the case of credit and financial institutions a new designation is made pursuant to Article 26(4) of Regulation (EU) 2024/1624;
when there is a change in the due diligence data of an existing customer, beneficial owner, or entity or person that controls or meets the ownership conditions under Article 20(1), point (d), of Regulation (EU) 2024/1624, such as but not limited to a change of name, residence, nationality or business operations, or a change in beneficial owner or designation of beneficiary, which may have a potential impact on the designation as a listed person, body or entity;
screen their customers, beneficial owners and entities or persons that control or meet the ownership conditions under Article 20(1), point (d), of Regulation (EU) 2024/1624 on a regular basis with a frequency that is commensurate with the exposure of the obliged entity and the business relationship to risks of non-implementation and evasion of targeted financial sanctions;
ensure that the screening and verification are performed without undue delay from the moment the UN financial sanctions are made public;
ensure that the screening and verification are performed without undue delay from the moment the updated targeted financial sanctions are applicable.
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.
Definition
crypto-asset services
Definition
financial mixed activity holding company
Definition
crypto-asset service provider
Definition
funds or other assets
Definition
credit institution
- a credit institution as defined in Article 4(1), point (1), of Regulation (EU) No 575/2013;
- a branch of a credit institution, as defined in Article 4(1), point (17), of Regulation (EU) No 575/2013, when located in the Union, whether its head office is located in a Member State or in a third country;
Definition
UN financial sanctions relating to proliferation financing
- UNSC Resolution 1718 (2006) and any successor resolutions;
- UNSC Resolution 2231 (2015) and any successor resolutions;
- any other UNSC resolutions imposing asset freezing and prohibitions to make funds or other assets available in relation to the financing of proliferation of weapons of mass destruction;
Definition
crypto-asset
Definition
property
Definition
express trust
Definition
legal arrangement
Definition
UN financial sanctions
- UNSC Resolution 1267 (1999) and its successor resolutions;
- UNSC Resolution 1373 (2001), including the determination that the relevant sanctions will be applied to the person or entity and the public communication of that determination;
- UN financial sanctions relating to proliferation financing;
Definition
targeted financial sanctions
Definition
financial institution
- an undertaking other than a credit institution or an investment firm, which carries out one or more of the activities listed in points (2) to (12), (14) and (15) of Annex I to Directive 2013/36/EU of the European Parliament and of the Council(32), including the activities of currency exchange offices (bureaux de change), but excluding the activities referred to in point (8) of Annex I to Directive (EU) 2015/2366, or an undertaking the principal activity of which is to acquire holdings, including a financial holding company, a mixed financial holding company and a financial mixed activity holding company;
- an insurance undertaking as defined in Article 13, point (1), of Directive 2009/138/EC of the European Parliament and of the Council(33), insofar as it carries out life or other investment-related assurance activities covered by that Directive, including insurance holding companies and mixed-activity insurance holding companies as defined, respectively, in Article 212(1), points (f) and (g), of Directive 2009/138/EC;
- an insurance intermediary as defined in Article 2(1), point (3), of Directive (EU) 2016/97 where it acts with respect to life insurance and other investment-related insurance services, with the exception of an insurance intermediary that does not collect premiums or amounts intended for the customer and which acts under the responsibility of one or more insurance undertakings or intermediaries for the products which concern them respectively;
- an investment firm as defined in Article 4(1), point (1), of Directive 2014/65/EU of the European Parliament and of the Council(34);
- a collective investment undertaking, in particular:
- an undertaking for collective investment in transferable securities (UCITS) as defined in Article 1(2) of Directive 2009/65/EC and its management company as defined in Article 2(1), point (b), of that Directive or an investment company authorised in accordance with that Directive and which has not designated a management company, that makes available for purchase units of UCITS in the Union;
- an alternative investment fund as defined in Article 4(1), point (a), of Directive 2011/61/EU and its alternative investment fund manager as defined in Article 4(1), point (b), of that Directive that fall within the scope set out in Article 2 of that Directive;
- a central securities depository as defined in Article 2(1), point (1), of Regulation (EU) No 909/2014 of the European Parliament and of the Council(35);
- a creditor as defined in Article 4, point (2), of Directive 2014/17/EU of the European Parliament and of the Council(36) and in Article 3, point (b), of Directive 2008/48/EC of the European Parliament and of the Council(37);
- a credit intermediary as defined in Article 4, point (5), of Directive 2014/17/EU and in Article 3, point (f), of Directive 2008/48/EC, when holding the funds as defined in Article 4, point (25), of Directive (EU) 2015/2366 in connection with the credit agreement, with the exception of the credit intermediary carrying out activities under the responsibility of one or more creditors or credit intermediaries;
- a crypto-asset service provider;
- a branch of a financial institution referred to in points (a) to (i), when located in the Union, whether its head office is located in a Member State or in a third country;
Definition
third country
Definition
funds
Definition
beneficial owner
Definition
business relationship