Published by the Luxembourg Bankers’ Association (ABBL) on 8 May 2026, this consultation response to AMLA’s draft Regulatory Technical Standards on business relationships, occasional transactions and linked transactions calls for greater legal certainty around key AML/CFT concepts. The ABBL advocates a proportionate approach ensuring that due diligence obligations are triggered by genuine economic relationships and meaningful transactional connections, while avoiding interpretations that could extend AML/CFT requirements to incidental, intermediary-based or purely technical interactions with limited AML/CFT relevance.
