Business Relationships, Occasional Transactions and Linked Transactions under Art. 19(9) AMLR
With the Draft Regulatory Technical Standards (RTS) under Article 19(9) of Regulation (EU) 2024/1624 (AMLR), AMLA has operationalised one of the most critical structural elements of the new EU AML framework: the correct identification of business relationships, occasional transactions, and linked transactions.
This is not a cosmetic clarification. It fundamentally harmonises how customer due diligence (CDD) triggers are determined across the Union and significantly affects onboarding logic, aggregation systems and threshold monitoring.
The RTS will apply from 10 July 2027.
Why Article 19(9) AMLR matters
Article 19 AMLR determines when CDD must be applied:
- When establishing a business relationship
- When carrying out an occasional transaction above EUR 10,000 (or sector-specific lower thresholds)
- When transactions are linked and cumulatively exceed the threshold
The correct classification of a customer interaction is therefore the first and decisive compliance step.
Article 19(9) AMLR mandates AMLA to specify:
- Criteria for identifying business relationships
- Criteria for identifying occasional transactions
- Criteria for identifying linked transactions
- Whether additional lower thresholds are necessary
The new RTS now provide these criteria in a harmonised and supervisory-testable manner.
Business Relationships under the New RTS
The Definition Remains in AMLR
A business relationship under AMLR exists where:
- A professional relationship is established, and
- It is expected to have, or later acquires, an element of repetition or duration
The RTS do not replace this definition.
They provide criteria that must at least be taken into account.
Registration-Based Online Access = Duration Indicator
A key horizontal criterion now applies to all obliged entities:
The use of online services via registration providing ongoing access must be taken into account when assessing duration.
This affects:
- Online gambling platforms
- Payment service providers
- Crypto-asset service providers
- Digital onboarding models
Registration-based access strongly indicates an element of duration and therefore may establish a business relationship even before repeated transactions occur.
This materially affects digital business models.
Sector-Specific Repetition Criteria
AMLA adopted a targeted approach where supervisory fragmentation existed.
Non-Financial Sector (Lawyers, Notaries, TCSPs, etc.)
Repetition must take into account:
- Services provided at different intervals
- Provision of different categories of services
Even without a formal long-term contract, ongoing engagement may create a business relationship.
Currency Exchange, Money Remittance and Certain CASPs
Three or more transactions within a rolling 12-month period must be taken into account when assessing repetition.
Key implications:
- Rolling period, not calendar year
- Cumulative logic required
- System-based transaction counters necessary
This introduces a semi-quantitative operational threshold for repetition.
Gambling Providers
Membership engagement may indicate repetition.
Football Clubs
Conditional player transfers (e.g. bonus clauses, contingent payments) may create repetition.
This shows AMLA’s sector-sensitive risk approach.
Occasional Transactions – Defined Negatively
The RTS define an occasional transaction as:
A transaction (or service connected to a transaction) not carried out as part of a business relationship.
Business relationships and occasional transactions are mutually exclusive.
This clarification is particularly important for:
- Real estate agents
- Notaries
- Intermediaries
- Service providers not directly executing transactions
If no repetition or duration exists, the activity defaults to an occasional transaction.
Linked Transactions – The Core Anti-Structuring Tool
The most operationally significant part of the RTS concerns linked transactions.
AMLR defines linked transactions as two or more transactions with:
- Identical or similar origin
- Identical or similar destination
- Identical or similar purpose
- Or other relevant characteristics
- Over a specific period
The RTS now specify criteria for each element.
Identical or Similar Origin / Destination
Must consider:
- Transactions by the same person
- Family members (if information available)
- Business partners
- Beneficial owners of the same parent undertaking
- Customers operating in concert
- Use of the same digital infrastructure (IP address, device ID, geolocation)
- Common intermediaries
This explicitly addresses digital structuring schemes.
Identical or Similar Purpose
Must consider:
- Transactions linked to the same purchase
- Same invoice, booking or order
- Instalment payments
Artificial splitting of a single purchase will no longer avoid CDD.
Other Relevant Characteristics
Includes:
- Circular flows of funds
- Synchronized transactions
- Transactions via networks of agents
- Loyalty programme participation
- Transaction dependency chains
This broadens aggregation logic beyond traditional same-customer structuring.
The “Information Available” Principle
A critical proportionality safeguard:
Obliged entities must consider criteria only if information:
- Is available, or
- Should be available under other regulatory obligations.
No new standalone data-collection obligation is created solely for RTS compliance.
Specific Period – Rolling One-Month Rule (Selected Sectors)
For:
- Currency exchange offices
- Money remittance providers
- Certain CASPs
Linked transactions must at least consider a rolling one-month aggregation period.
This creates a hard aggregation timeframe for higher-risk sectors.
No Additional Lower CDD Thresholds
AMLA assessed whether new lower thresholds should be introduced below EUR 10,000.
Conclusion:
- No additional lower thresholds at this stage.
- Existing sector-specific thresholds in AMLR remain sufficient.
- Future amendments remain possible if risk evidence emerges.
This reflects proportionality and simplification.
Operational and Compliance Impact
The RTS will affect:
- Onboarding classification logic
- CRM system design
- Transaction monitoring engines
- Aggregation algorithms
- Digital infrastructure detection
- Documentation standards
Supervisors will test:
- Whether repetition logic is implemented
- Whether rolling periods are operationalised
- Whether linked transaction criteria are embedded in systems
- Whether classification decisions are documented
Static threshold tables will no longer be sufficient.
Key Takeaways
From 2027 onwards:
- Registration-based online services strongly indicate business relationships.
- Three transactions in 12 months may indicate repetition (selected sectors).
- Linked transaction detection becomes structurally harmonised.
- Digital infrastructure becomes relevant for structuring analysis.
- No additional monetary thresholds are introduced.
- Aggregation logic must be systemically implemented.
Article 19(9) AMLR shifts CDD from static threshold application to structured, risk-sensitive trigger architecture.
For obliged entities, this is not a documentation update. It is a system architecture issue.