ALFI responds to AMLA consultation paper on draft RTS on Criteria for business relationships
15 May 2026 | Statements and Position Papers
On 8 May 2026, ALFI submitted its response to AMLA's consulation on Criteria for business relationships, occasional transactions and linked transactions as well as lower thresholds under Article 19 (9) of Regulation (EU) 2024/1624.
In its response to the consultation on Criteria for business relationships, occasional transactions and linked transactions, ALFI also insists that AMLA address the intermediated distribution model explicitly and confirm among other that the business relationship exists between the fund and its direct counterparty (i.e. the subscribing intermediary) and not between the fund and the intermediary’s underlying investors.
AMLA is expected to submit the final draft RTS to the European Commission by 10 July 2026.
View the ALFI response.