Occasional transaction or business relationship? How AMLA draws the line

What is the RTS on Article 19(9) AMLR?

The RTS under Article 19(9) is a draft delegated regulation that specifies how obliged entities distinguish a business relationship from an occasional transaction, and how they identify linked transactions. Article 19(9) AMLR gives AMLA four jobs:

1. identify the high-risk activities that justify a lower CDD threshold,
2. set those thresholds,
3. define the criteria for a business relationship and an occasional transaction,
4. and define the criteria for linked transactions.

The text is still a draft. It must be adopted by the European Commission and then published in the Official Journal of the European Union (final report, p. 2). It is part of the EU AML package and of AMLA's technical standardisation work.

Occasional transaction or business relationship: why the first call matters

Classification is the first decision in an AML/CFT framework. A business relationship triggers customer due diligence (CDD) whatever the amount (AMLR, art. 19(1)(a)), followed by ongoing monitoring. An occasional transaction only triggers it once a threshold is reached, whether in a single operation or through linked transactions (art. 19(1)(b)). Get the classification wrong and you either skip CDD you owed, or run it where it was never required.

AMLA stepped in because supervisors kept seeing the same two problems: some entities struggle to tell the two concepts apart, and approaches differ across member states, especially in the non-financial sector (final report, p. 19). The classification also feeds the data you report to supervisors, such as your number of customers and of occasional transactions (p. 16).

What the RTS actually says

Article 1: an occasional transaction is what a business relationship is not

The AMLR defines a business relationship (art. 2(1), point 19) and linked transactions (point 20), but never says what an occasional transaction is. The RTS fills that gap: an occasional transaction is "a transaction or the provision of services connected to a transaction" that is not carried out as part of a business relationship (art. 1). The two are mutually exclusive, and only activities within the AML/CFT scope count (recital 5).

Estate agents, notaries and other professions that provide services connected to a transaction, rather than carrying it out, assess the threshold on the value of the underlying transaction, excluding transaction or service fees (recital 6).

Article 2: the signs of a business relationship

Under the AMLR, a business relationship is one that is expected to last or to repeat. Article 2 tells you what to look for.

One sign applies to everyone: ongoing access. If a customer can keep using your AML/CFT services, for example through a customer account, that points to a relationship that lasts. A newsletter sign-up or access to information pages does not count (art. 2(1), recital 7). The consultation draft used online registration as the sign instead, until more than sixty respondents pushed back (final report, p. 27-28).

The other signs are sector-specific:

• Advisory, legal and real estate professions* look at whether a service takes several actions over a substantial period, whether they serve the customer at different intervals, and whether they provide different services (art. 2(2) and 2(3)).
• Currency exchange, money remittance and certain crypto-asset services treat three or more transactions in the last twelve months as repetition (art. 2(4)).
• Gambling services on physical premises look at whether the customer joined a voluntary membership scheme (art. 2(5)).
• Football agents and professional football clubs look at conditional obligations attached to a player transfer (art. 2(6)).

*Auditors, external accountants, tax advisers, notaries, lawyers and other independent legal professionals, trust or company service providers, estate agents and other real estate professionals, investment migration operators.

Article 3: when separate transactions count as one

Under the AMLR, linked transactions are two or more transactions with identical or similar origin, destination and purpose, or other relevant characteristics, over a specific period of time. The RTS asks you to look at all the facts and circumstances together, using thirteen criteria (art. 3(1)):

• Origin and destination: same natural or legal person; customers who are members of the same family, business partners, acting in concert, or subsidiaries or beneficial owners of the same parent company; same digital infrastructure (IP address, device identifier, geolocation); common intermediaries or service providers.
• Purpose: transactions relating to the same purchase, for example a common invoice, booking or order (recital 12).
• Other relevant characteristics: common characteristics, such as circular movements of funds or synchronised transactions; same origin and destination through different establishments, agents, distributors or channels; same origin in a loyalty programme; a transaction conditional on the prior completion of other transactions processed by the same entity.
• Specific period of time: a short period, assessed according to the nature of the activity, the speed and frequency of the transactions and the size of the entity.

For gambling, Article 3(3) adds the criterion of games provided by the same provider. For currency exchange, money remittance and the crypto-asset services concerned, the period to consider is at least one month (art. 3(2)).

No single criterion decides, and you cannot dismiss one just because it does not decide on its own (recital 10). Eight of the criteria only apply to information you hold or should hold. You do not have to collect new data just to find linked transactions (recital 10; final report, p. 33).

The target is structuring: splitting a payment to stay under a threshold. The logic is not new. The Transfer of Funds Regulation (TFR) already adds up transfers that appear to be linked when it applies its EUR 1,000 threshold.

Occasional transaction thresholds do not move

AMLA had the power to set lower thresholds for high-risk activities. It chose not to: it found no conclusive evidence that they were necessary and proportionate (final report, p. 23-24), and around 120 consultation respondents agreed (p. 34). The AMLR thresholds stay the only ones that apply:

• EUR 10,000, full CDD. Occasional transactions, in a single operation or through linked transactions (art. 19(1)(b)).
• EUR 1,000, full CDD. Transfers of funds by credit and financial institutions (art. 19(2)).
• EUR 1,000, full CDD. Occasional transactions by crypto-asset service providers (art. 19(3)(a)).
• EUR 3,000, at least identification and verification. Occasional cash transactions (art. 19(4)).
• EUR 2,000, full CDD. Gambling: winnings, stakes, or both (art. 19(5)).

If new evidence emerges, AMLA can still propose an amendment with a lower threshold (p. 6).

What the RTS does not settle yet

Three points to keep an eye on before you configure anything.

1. A contradiction in the report. On page 29, the final report says that a single element of Articles 2(2) or 2(3) "is sufficient" to establish a business relationship. Recital 4 and the rest of the report say the opposite: no criterion settles it on its own. AMLA will publish a factsheet when it submits the report to the Commission, and more non-binding explanatory material after adoption. That should clear it up (p. 29).
2. Two language versions, two definitions. In English, the AMLR defines a business relationship by an element of "repetition or duration". The French version says "répétitif et durable" (repetitive and lasting). The RTS looks at each element separately. The difference matters, for example, for a single-premium life insurance contract with no further transactions.
3. A tight timeline. The AMLR applies from 10 July 2027 (art. 90). The RTS enters into force twenty days after publication and applies six months later. To apply on the same day as the AMLR, it would have to be published by around 21 December 2026.

What about insurers?

The RTS has nothing specific for insurers. An insurance undertaking is only an obliged entity for its life and other investment-related activities (AMLR, art. 2(1), point 6(b)). Non-life business stays out of scope, so a composite insurer has to separate the two. In life insurance, the contract is built to last, so CDD applies whatever the amount. The sector-specific rules stay in the AMLR: CDD on beneficiaries (art. 47) and, when CDD cannot be completed, refraining from transactions rather than terminating the contract (art. 21). More on how we approach the sector on our insurance page.

What this means for your systems

The RTS adds no new CDD measure. What it adds is a burden of proof: you have to show that you took the criteria into account, including when none of them applies. In practice, that takes six capabilities.

• An explicit, reasoned classification status. Every AML/CFT interaction is either a business relationship or an occasional transaction. There is no room for "unclassified".
• Rolling counters. For currency exchange, money remittance and the crypto-asset services concerned, transactions are counted per customer over a rolling twelve months, and aggregation covers at least one month.
• Multiple aggregation keys. Customer identifier, links between persons and companies (family, partners, beneficial owners), shared digital infrastructure (IP address, device), intermediary, purchase reference, channel or agent.
• A documented aggregation window. You set the "short period" per activity, based on how fast and how often transactions happen, and you write down why.
• Data minimisation. The criteria that depend on available information run on data you already hold, with no extra collection.
• A traceable human decision. An overall assessment is not an automated rule. Every criterion you assessed, present or absent, and the final call must leave an audit trail.

Several respondents warned that criteria such as family ties or shared digital infrastructure could produce false positives (final report, p. 31-32). That is where automated signals need human judgement, just as with false positives in AML.

Frequently asked questions

What is the RTS on Article 19(9) AMLR?

It is a draft regulatory technical standard developed by AMLA. It specifies the criteria for distinguishing a business relationship from an occasional transaction and for identifying linked transactions, and examines whether lower CDD thresholds are appropriate. The final report is dated 30 September 2026.

When will the RTS on Article 19(9) apply?

It will apply six months after its entry into force, which is itself set at the twentieth day following its publication in the Official Journal. For football agents and professional football clubs, it will apply from 10 July 2029 (art. 4).

What is the difference between a business relationship and an occasional transaction?

A business relationship has, from the first contact or later, an element of repetition or duration (AMLR, art. 2(1), point 19). An occasional transaction is any transaction carried out outside a business relationship (RTS, art. 1). The first triggers CDD regardless of the amount, the second from a threshold.

When is customer due diligence required under the AMLR?

Always for a business relationship, whatever the amount (AMLR, art. 19(1)(a)). For an occasional transaction, from a threshold, including when that amount is reached through linked transactions: EUR 10,000 as a general rule, with lower thresholds for transfers of funds, crypto-assets, cash and gambling (art. 19).

What are linked transactions under the AMLR?

They are two or more transactions with identical or similar origin, destination and purpose, or other relevant characteristics, over a specific period of time (AMLR, art. 2(1), point 20). Their amounts are added together to assess the CDD thresholds.

Has AMLA lowered the CDD thresholds?

No. The final report does not create any additional threshold. The thresholds in Article 19 AMLR remain applicable: EUR 10,000 as a general rule, EUR 1,000 for transfers of funds and crypto-assets, EUR 3,000 for cash, EUR 2,000 for gambling.