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Written by the team at Shoulder Compliance, Malta.

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14/10/2026

Cross-Border Groups Under the AMLR

Cross-Border Groups Under the AMLR

Picture a payments group with its parent in Malta and subsidiaries in Ireland, Lithuania and Germany. Today each entity may follow a slightly different local manual. Under Regulation (EU) 2024/1624, that is harder to defend.

What Article 16 asks of the parent

Article 16 puts group-wide requirements on the parent undertaking, defined in Article 2(1)(42). The parent must make sure its internal procedures, risk assessment and staff requirements reach every branch and subsidiary. It prepares a group-wide risk assessment drawing on each entity’s own assessment, sets group policies, and appoints a group compliance manager. That manager reports to the parent’s management body at least once a year on implementation and on fixing deficiencies.

Information sharing

Group entities must share information relevant to customer due diligence and risk management: who the customer and beneficial owner are, why the relationship exists, and suspicions reported to the FIU together with their analysis, unless the FIU instructs otherwise. The parent has to put confidentiality and data-protection safeguards around that sharing.

Standards still in motion

Article 16 told AMLA to submit draft technical standards on minimum group-wide requirements by 10 July 2026. Check AMLA’s website for the current status before you design anything on a draft. See also Regulation (EU) 2024/1620, which created the authority.

Our view

The group compliance manager role is the part groups underestimate. It cannot be a title for someone already running one subsidiary’s MLRO desk. Decide who owns the group view before the standards are final, because the reporting line matters more than the wording of the policy.

What this means for you

Draw your group chart, mark which entities are obliged entities, and identify the parent in the Article 2(1)(42) sense. For help with that, use the enquiry form or schedule a no-obligation call. Related: AMLR in the EU, payments and e-money, AMLA direct supervision.

General information, not legal advice.

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