Global Digital Finance (GDF) submitted a response to the Anti-Money Laundering Authority’s (AMLA) consultation on draft Regulatory Technical Standards under Article 19(9) of Regulation (EU) 2024/1624 relating to business relationships, occasional transactions, linked transactions, and lower thresholds.
GDF broadly supports AMLA’s principles-based and proportionate approach aimed at reducing fragmentation across Member States and sectors. The response welcomes the inclusion of online registration as a criterion relevant to establishing a business relationship and supports AMLA’s decision not to introduce additional lower thresholds for occasional transactions at this stage.
The submission provides targeted recommendations to improve clarity and operational consistency for cryptoasset service providers (CASPs), including clarification of the interaction between onboarding processes and ongoing business relationships, proportional application of linked transaction criteria, and recognition of blockchain analytics as a valid evidential tool. GDF also encourages AMLA to ensure that technical indicators such as IP addresses and geolocation data are not treated as standalone indicators of linked transactions and that implementation remains consistent with data protection obligations.
Overall, GDF supports the adoption of a workable and proportionate framework that promotes supervisory consistency while recognising the operational characteristics of digital asset business models.
Submitted:
17/04/2026