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ABBL response to AMLA consultation on draft Customer Due Diligence RTS submitted on 8 May 2026 advocates a risk-based and technology-neutral framework

Published on 18 June 2026

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Executive summary

Published by the Luxembourg Bankers’ Association (ABBL) on 8 May 2026, this consultation response to AMLA’s draft Regulatory Technical Standards on Customer Due Diligence calls for a genuinely risk-based and technology-neutral CDD framework. The ABBL advocates recognition of reliable digital verification solutions, proportionate documentary and remediation requirements, and greater legal certainty regarding ownership structures. It also emphasises that institutions should not be expected to identify, verify or monitor customers with whom they have neither direct access nor a business relationship.

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