Source: AMLA final report draft
- Anti-money laundering
AMLAR supplemental acts
- RTS on risk assessment to select institutions for direct supervision
Article 4 Assessment and classification of the residual risk at entity level
This is a draft act
This text has been parsed from the AMLA final report draft as published on 16 December 2025. 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 4 of the RTS on risk assessment to select institutions for direct supervision say?
Article 4 is the culminating step in a sequential risk assessment process, bringing together the outputs of Articles 2 and 3 to produce a final residual risk classification for credit and financial institutions.
While Articles 2 and 3 establish how to score inherent risk and controls quality respectively, this article explains how those two scores are combined into a single residual risk score, and how that score is then converted into one of four classifications: low, medium, substantial, or high.
The key mechanic is that good controls can reduce but never worsen an institution's residual risk — if controls quality is better than the inherent risk score, the residual risk simply equals the inherent risk; if controls quality is worse, the residual risk is the average of the two scores.
Important points:
- The residual risk score for credit and financial institutions is derived by combining the inherent risk score from Article 2 and the controls quality score from Article 3 using a specific two-rule formula.
- Strong AML/CFT controls can cap but not reduce the residual risk below the inherent risk score — meaning inherent risk always sets the floor.
- The final residual risk classification falls into one of four categories — low, medium, substantial, or high — determined by fixed numerical score thresholds.
Springlex's summary of the article, a reading aid, not a substitute for the legal text.
The methodology for assessing and classifying the residual risk profile of a credit institution or financial institution, as referred to in Article 12, paragraph (5) and (6), of Regulation (EU) 2024/1640 as low, medium, substantial or high, shall consist of the following sequential steps:
based on the inherent risk score and the controls quality score attributed to the credit or financial institution, in accordance with Article 2 and Article 3, determining the residual risk score of the credit and financial institutions by applying the following rules:
where the controls quality score is greater than the inherent risk score, the residual risk score shall be equal to the inherent risk score;
where the controls quality score is lower than or equal to the inherent risk score, the residual risk score shall be equal to the average of the inherent risk score and the controls quality score;
depending on the residual risk score of the credit institution or financial institution, determined in accordance with point (a), classifying the residual risk profile of the credit institution or financial institution as low, medium, substantial or high, in accordance with the following conversion rules:
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
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
crypto-asset
Definition
property
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