ALFI responds to AMLA’s consultation on the proposed RTS under Article 53(10) AMLD6
12 March 2026 | Statements and Position Papers
On 9 March 2026, ALFI submitted its response to AMLA's consultation on the proposed Regulatory Technical Standards on pecuniary sanctions, administrative measures and periodic penalty payments, developed pursuant to Article 53(10) of Directive (EU) 2024/1640 (AMLD6).
In its response, ALFI highlights the importance of proportionality in the design of the sanctions framework, particularly regarding the calibration of breach severity indicators and the personal liability of compliance professionals within the three-lines-of-defence model.
ALFI also stresses that the most severe administrative measures should be reserved for the highest gravity breaches, and warns AMLA of the risk of deterring experienced compliance talent and weakening institutional governance if the current approach is maintained.
AMLA is expected to submit the final draft RTS to the European Commission by 10 July 2026.
View the ALFI response.