EBF feedback on AMLA Draft RTS on group-wide minimum requirements

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Brussels, 22 June 2026 -The European Banking Federation (EBF) has submitted its feedback on AMLA's Draft Regulatory Technical Standards on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries under Articles 16(4) and 17(3) of the AMLR.

The EBF supports a framework that is firmly anchored in the risk-based approach (RBA). However, we are concerned that several proposed requirements appear to go beyond the AMLR, including the introduction of a mandatory group AML/CFT officer and additional measures applicable to branches and subsidiaries of EU obliged entities and parent undertakings located in third countries.

The EBF also calls for a practical and workable parent undertaking model, with clear governance and coordination arrangements to ensure consistent implementation of group-wide policies and procedures. Entities should not be held accountable for implementation across affiliates without having the necessary authority or means to ensure compliance, thereby avoiding a "responsibility without authority" outcome.

Finally, the EBF recommends that AMLA publish and maintain a list of third countries that restrict intra-group information sharing and reiterates its call for a reassessment of the additional measures applicable to third-country branches and subsidiaries, with a view to ensuring greater alignment with the risk-based approach.

Read the full document here

For more information:

Roger Kaiser, Head of Tax and Compliance - r.kaiser@ebf.eu
Anna Maria Nowak, Policy Advisor - Tax and Compliance - am.nowak@ebf.eu

About the EBF:

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.