Business-Wide Risk Assessment under AMLR Article 10
The Anti-Money Laundering Regulation applies from 10 July 2027. From that date, the AML business-wide risk assessment stops being a document assembled from scattered guidance and becomes a named legal duty with its own article.
The term business-wide does not appear once in the fourth and fifth Anti-Money Laundering Directives. It appears thirteen times in Regulation (EU) 2024/1624, six of them inside Article 10 alone.
This seminar is built for the people who have to produce that assessment, defend it and keep it current, rather than for people meeting the idea for the first time.
What you will learn
- What Article 10 requires, as specific obligations in an order you can work through.
- How to extract and apply the sources the article names, which is the method rather than the reading. Reading a long national assessment is the easy half. Pulling out what is genuinely about your firm, and getting it into your own document in a form somebody else can follow, is the skill the seminar spends most of its time on.
- What supervisors look for, in their own published words, and what they say when they are not satisfied.
- How real assessments failed, read from a regulator decision and from a thematic review of firms in one market.
- How to score inherent risk and control quality, including why a control is assessed on two questions rather than one.
- How to build your own assessment, from a blank workbook to a board-approved document.
Who should attend
Money laundering reporting officers, compliance officers and their deputies, internal auditors, risk officers, and directors of regulated firms. It is written for any obliged entity in the financial sector, including credit institutions, investment firms, payment and electronic money institutions, crypto-asset service providers, fund managers and administrative service providers, and it is suitable for holders of CySEC certifications who need continuing professional development in anti-money laundering.
Regulatory frameworks covered
- Regulation (EU) 2024/1624, the Anti-Money Laundering Regulation, and Article 10 in particular.
- Directive (EU) 2024/1640, the sixth Anti-Money Laundering Directive, and how a directive binds differently from a regulation.
- The AMLA consultation paper on draft guidelines on business-wide risk assessment under Article 10(4), which sets out four minimum requirements. These guidelines are still in consultation and the seminar says so wherever it relies on them.
- The final report on draft regulatory technical standards under Article 40(2) of Directive (EU) 2024/1640, whose annex carries the risk indicators. These standards are with the Commission and await adoption.
CPD hours and format
Five hours, carrying five CPD units. The course is on demand, so it can be paused and resumed. It comprises eleven narrated video lessons with burned-in captions, a 184-slide presentation, a reading lesson of 21 minutes, and a ten question assessment with a pass mark of 70 per cent. The assessment can be retaken.
Practical elements
The seminar walks the published sources one at a time rather than describing them. It opens the European Banking Authority opinion on the money laundering and terrorist financing risks affecting the financial sector of the Union, a national risk assessment and a sectoral one, an outside evaluation of a country against the international standards, and the annual report of a financial intelligence unit. Each is read the way a compliance officer has to read it, looking for the paragraph that changes a rating.
It then reads real enforcement. A regulator refusing a registration and publishing the weaknesses it found in the business-wide risk assessment, a thematic paper setting out good and poor practice across many firms, three administrative measures published by a financial intelligence unit with the power to fine, and the final notice against Monzo, the digital challenger bank, carrying a penalty of 21,091,300 pounds.
The course includes an Excel workbook of 22 tabs covering ten firm types, built around the four minimum requirements and the published risk indicators. The final section walks it tab by tab. The workbook is supplied free with the course. Completing it is entirely optional, nothing in it is marked and nothing is submitted.
Free companion resources
Two free resources accompany this seminar. Both are available to registered CPDs.Academy users at no cost.
Read first. The blog article Business-Wide Risk Assessment Under AMLR walks through how Article 10 of the AMLR, the AMLA draft Guidelines under Article 10(4) AMLR, and the AMLA Final Report on the RTS under Article 40(2) AMLD fit together. Useful as orientation before the seminar. Read the article
Use alongside the seminar. The AMLR Article 10 BWRA Workbook is a free Excel file that operationalises the three-step methodology for ten sectors of obliged entities in one file. Inherent risk in Section A. Controls quality in Section B. Residual risk with an MLCO override in Section C. A separate Targeted Financial Sanctions Risk Assessment is included. Download the workbook
The seminar provides the framework, methodology and supervisory expectations. The article orients you. The workbook helps you apply what you have learned inside your own firm.
The companion course on customer risk assessment covers the client level assessment that this one sits above. The two work together, because the business-wide assessment sets the frame within which customer assessments operate, and the data coming back from those assessments is what tests whether the frame still holds.
Course program
Certificate
A certificate is given at the end of the course.
The course will be available 180 Day