EBF - European Banking Federation

06/22/2026 | Press release | Distributed by Public on 06/22/2026 05:57

EBF feedback on AMLA Draft Regulatory Technical Standards (RTS) on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries[...]

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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.

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