Response to Consultation on draft Regulatory Technical Standards on group-wide requirements under Article 16(4) of Regulation (EU) 2024/1624 and on additional measures on branches andsubsidiaries in third countries under Article 17(3)of Regulation (EU) 2024/1624

Were are pleased to herewith provide comments on the public consultation on the draft Regulatory Technical Standards (RTS), as published on the Anti-Money Laudering Authority’s (AMLA) website on 16 April 2026 (Consultation Paper).

The comments in this document will focus on the Draft RTS on supplementing Regulation (EU) 2024/1624of the European Parliament and of the Council (the AMLR) with regard to regulatory technical standards ongroup-wide requirements, on additional measures and additional supervisory actions related to obligedentities’ branches or subsidiaries in third countries (draft RTS on group-wide requirements under Article16(4) of the AMLR and on additional measures on branches and subsidiaries in third countries under Article17(3) of the AMLR).