AMLR Article 10 Business-Wide Risk Assessment Workbook

Status note. This workbook reflects regulatory texts that are partly in consultation. The Final Report on the RTS under Article 40(2) AMLD was published by AMLA on 16 December 2025. The draft Guidelines on Business-Wide Risk Assessment under Article 10 (4) AMLR are in public consultation, with the AMLA public hearing on 28 May 2026 and the consultation deadline on 15 July 2026. AMLA expects to issue the final Guidelines in Q4 2026. A revised version of this workbook will follow once the final Guidelines are issued.

A free Excel workbook that operationalises Article 10 of Regulation (EU) 2024/1624 (AMLR) for ten sectors of obliged entities in one file. Designed for MLCOs and Compliance Officers who are drafting or revising their Business-Wide Risk Assessment ahead of the AMLR application date.

The workbook starts from Annex I of AMLA's Final Report on the Draft Regulatory Technical Standards on the assessment of the inherent and residual risk profile of obliged entities under Article 40(2) of Directive (EU) 2024/1640. The same data points supervisors will use to score credit institutions and financial institutions are the data points an obliged entity is now expected to start from when identifying its inherent risks, as set out in paragraph 23 of AMLA's draft Guidelines on Business-Wide Risk Assessment under Article 10 (4) of the AMLR.

What is in the workbook

Three minimum requirements covered. Inherent risk in Section A. Controls quality in Section B, on the inverted scale that matches the supervisory risk assessment. Residual risk with an MLCO override in Section C. This mirrors paragraphs 23, 27 and 29 of the draft Guidelines.

Sector-specific scoping for ten categories of obliged entity. Credit institutions, investment firms, AIFMs and UCITS ManCos, EMIs, payment institutions, CASPs, life insurers, bureaux de change, asset managers, and other obliged entities. A short Services questionnaire auto-greys the indicators that do not apply to the entity, so a credit institution does not see AIF management and an AIFM does not see correspondent services.

A separate Targeted Financial Sanctions Risk Assessment. Addressing paragraphs 12 and 13 of the draft Guidelines. Section A risk drivers, Section B controls quality, Section C evidence base, auto-aggregating to a TFS final residual.

A Methodology Setup tab. The obliged entity defines its own band thresholds and category weights, with rationale fields. The workbook does not impose the calibration. Paragraph 15 of the draft Guidelines reminds us the obliged entity owns it.

Workbook contents

22 tabs. 2,609 formulas. 137 inherent indicators on the credit institution tab. 24 scored TFS topics. Ten sector worksheets in one file.

Who it is for

MLCOs and Compliance Officers at obliged entities across the EU, including credit institutions, CIFs, AIFMs, UCITS ManCos, EMIs, payment institutions, CASPs, life insurance undertakings, bureaux de change, and asset managers. Useful for entities of all sizes, but designed with smaller and medium-sized obliged entities in mind, given the proportionality framing of the draft Guidelines themselves.

How it relates to the Business-Wide Risk Assessment seminar

The CPDs.Academy seminar on Business-Wide Risk Assessment provides the underlying framework, methodology and supervisory expectations behind the workbook. The current seminar reflects the regulatory regime in force at the time of recording. The seminar will be updated to reflect the final AMLR Article 10 Guidelines once they are issued by AMLA in the coming months.

View the Business-Wide Risk Assessment seminar

Related reading

Business-Wide Risk Assessment Under AMLR — what the draft Guidelines and the RTS on Article 40(2) AMLD mean when read together

Sources

• Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR),Article 10 and related provisions.
• AMLA Final Report — Draft Regulatory Technical Standards on the assessment of the inherent and residual risk profile of obliged entities under Article 40(2) of Directive (EU) 2024/1640, published 16 December 2025.
• AMLA Consultation Paper on Draft Guidelines under Article 10 (4) AMLR, published 16 April 2026, consultation deadline 15 July 2026.
• EBA Guidelines on customer due diligence and the factors credit and financial institutions should consider when assessing the ML/TF risk associated with individual business relationships and occasional transactions (EBA/GL/2021/02).

If you find something to fix or extend, contact us. Practitioner feedback will be incorporated into the next version of the workbook.