GDF Response to AMLA Consultation Paper on Draft Regulatory Technical Standards on Business Relationships, Occasional Transactions and Linked Transactions
Global Digital Finance (GDF) submitted a response to the Anti-Money Laundering Authority’s (AMLA) consultation paper on the draft Regulatory Technical Standards specifying criteria for identifying business relationships, occasional transactions, and linked transactions under Article 19(9) of Regulation (EU) 2024/1624. The response broadly supports AMLA’s objective of reducing fragmentation across Member States and sectors and establishing a balanced, principles-based framework for anti-money laundering and counter-terorist financing obligations across the EU.
GDF welcomes the inclusion of online registration as a criterion for identifying business relationships, noting that this is well suited to crypto-asset service provider (CASP) business models where onboarding and customer due diligence are typically completed through digital registration processes. GDF also supports AMLA’s decision not to introduce additional lower thresholds for occasional transactions at this stage and welcomes the proportionate treatment of sector-specific requirements for CASPs.
The response recommends targeted clarifications to improve operational certainty and proportionality, particularly regarding when a business relationship should be considered established for CASPs, the application of linked transaction criteria, and the recognition of blockchain analytics as valid evidence for identifying common transaction characteristics. GDF also highlights the need to ensure that technical indicators such as IP addresses, device identifiers, geolocation, and common intermediaries are not treated as standalone indicators of linked transactions and should only be assessed alongside additional corroborating factors. The submission further addresses the proportionality of the rolling one-month linked transaction window, interaction with the Transfer of Funds Regulation, and the importance of aligning implementation with data protection requirements and broader compliance obligations across the sector.
Submitted:
17/04/2026