Statements on EU AML Authority Draft Standards submitted
PAC Statements 3/2026 and 4/2026 on Customer Due Diligence & on Business Relationships, Occasional & Linked Transactions and Lower Thresholds
CFE Tax Advisers Europe has submitted two Opinion Statements in response to consultations being carried out by the EU AML Authority on draft Regulatory Technical Standards being developed under the EU Anti-Money Laundering Regulation (AMLR), contributing to the ongoing development of the EU AML Single Rulebook.
The submissions concern draft RTS on:
- Customer Due Diligence obligations under Article 28(1) AMLR; and
- Criteria for identifying business relationships, occasional and linked transactions, and lower thresholds under Article 19(9) AMLR.
In both Statements, CFE supports the objective of a harmonised and effective EU AML/CFT framework while emphasising that the final standards must remain practical, workable, proportionate and genuinely risk-based, reflecting the realities of tax advisory practice across Europe.
The Statements stress that AML obligations designed primarily for financial institutions should not automatically be applied to professional advisory services without appropriate sectoral calibration. CFE highlights that the tax advisory profession contributes to AML prevention through long-term professional relationships, deep understanding of clients’ ownership structures and business activities, and the ability to identify inconsistencies and risks at an early stage.
Across both submissions, CFE calls for sector-specific guidance, legal certainty, consistency with professional secrecy obligations, and implementation measures that are operationally workable for non-financial professions.
