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)

    1. 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.

    1. For the purposes of paragraph 1, obliged entities shall:

      1. 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:

        1. 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;

        2. 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;

        3. 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;

      2. 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;

      3. 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:

        1. when entering into a business relationship or performing an occasional transaction;

        2. 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;

        3. 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;

      4. 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;

      5. ensure that the screening and verification are performed without undue delay from the moment the UN financial sanctions are made public;

      6. ensure that the screening and verification are performed without undue delay from the moment the updated targeted financial sanctions are applicable.

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