The Cyprus Securities and Exchange Commission (CySEC), through Announcement and Circular C755 dated 16 February 2026, has informed regulated entities of the Anti-Money Laundering Authority’s (AMLA) launch of public consultations on three important draft Regulatory Technical Standards (RTS).
These consultations form part of AMLA’s broader mandate to harmonise anti-money laundering and countering the financing of terrorism (AML/CFT) rules across the European Union and to ensure consistent supervision and enforcement.
This development is particularly relevant for Cyprus Investment Firms (CIFs), Administrative Service Providers (ASPs), UCITS Management Companies, AIFMs, Crypto Asset Service Providers (CASPs), Crowdfunding Service Providers, and other regulated entities under CySEC supervision.
A. The Three Draft RTS Under Consultation
AMLA is consulting on draft RTS under the following legal provisions:
1. Article 19(9) of Regulation (EU) 2026/1624 (AMLR)
Business Relationships, Occasional Transactions and Linked Transactions
This draft RTS sets out the criteria for identifying:
- Business relationships
- Occasional transactions
- Linked transactions
- Lower thresholds triggering AML obligations
These concepts form the structural basis upon which Customer Due Diligence (CDD) obligations apply. Clear and harmonised criteria are essential to ensure consistency across Member States and to reduce interpretative divergence in practice.
Deadline for submission of comments: 8 May 2026
2. Article 28(1) of Regulation (EU) 2024/1624 (AMLR)
Customer Due Diligence (CDD)
Customer due diligence remains a cornerstone of the EU AML framework. This draft RTS provides further detail on how obliged entities must:
- Verify customer identity
- Apply risk-based approaches
- Conduct ongoing monitoring
- Ensure proportionality in implementation
The objective is to ensure uniform standards across both financial and non-financial sectors, enhancing regulatory clarity and supervisory convergence.
Deadline for submission of comments: 8 May 2026
3. Article 53(10) of Directive (EU) 2024/1640 (AMLD 6)
Pecuniary Sanctions, Administrative Measures and Periodic Penalty Payments
This draft RTS focuses on enforcement and supervisory consistency. It aims to establish a common approach across the EU to:
- Assessing breaches of AML/CFT obligations
- Categorising violations
- Applying sanctions and administrative measures
The harmonisation of enforcement mechanisms is a critical step toward reducing regulatory fragmentation and strengthening compliance culture across the Union.
Deadline for submission of comments: 9 May 2026
B. Public Hearing – 24 March 2026
AMLA has scheduled an online Public Hearing on 24 March 2026 covering the draft RTS on Business Relationships and Customer Due Diligence. Further details will be published by AMLA in due course.
Participation in the hearing offers regulated entities an opportunity to gain practical insight into AMLA’s interpretative direction and supervisory expectations.
C. Particular Emphasis on Non-Financial Sector Participation
In its press release dated 9 February 2026, AMLA expressly welcomes responses from all stakeholders, and particularly encourages input from the non-financial sector. This follows limited participation in previous EBA consultations in early 2025.
The expanding scope of AML/CFT obligations means that non-financial obliged entities must carefully assess how the forthcoming RTS will impact their policies, procedures, and internal controls.
D. AMLA’s Strategic Direction: Single Programming Document 2026–2028
CySEC also highlighted AMLA’s Single Programming Document (SPD) for 2026–2028. This document outlines AMLA’s strategic priorities and work programme and provides the market with valuable visibility regarding upcoming regulatory mandates.
For regulated entities, the SPD is a critical forward-looking document, allowing early preparation for:
- Harmonised supervisory methodologies
- Enhanced enforcement coordination
- Additional RTS and implementing standards
Proactive review of the SPD will assist firms in aligning their compliance frameworks with the evolving EU AML architecture.
E. Why This Matters for Regulated Entities
The AMLR and AMLD 6 represent a fundamental shift toward deeper harmonisation of AML/CFT standards across the EU. These draft RTS will shape:
- How business relationships are classified
- How customer due diligence is operationalised
- How supervisory breaches are assessed and sanctioned
Entities that engage early in the consultation process will be better positioned to:
- Anticipate regulatory expectations
- Adjust internal AML manuals and procedures
- Avoid future compliance gaps
- Influence practical implementation challenges
F. How We Can Assist
We encourage regulated entities to review the draft RTS and consider submitting reasoned responses within the consultation deadlines.
Our firm is available to:
- Analyse the draft RTS and assess their impact on your organisation
- Prepare consultation submissions on your behalf
- Review and update AML policies and procedures
- Provide targeted training to compliance officers and boards
- Align your framework with AMLA’s upcoming supervisory expectations
Should you wish to discuss how these developments may affect your organisation, please do not hesitate to contact us.
Disclaimer: The information contained in this article is provided for informational purposes only, and should not be construed as legal advice on any matter. Andria Papageorgiou Law Firm is not responsible for any actions (or lack thereof) taken as a result of relying on or in any way using information contained in this article and in no event shall be liable for any damages resulting from reliance on or use of this information.
