ECG responds to AMLA consultation on draft RTS on group-wide AML/CFT requirements

On 15 June 2026 the European Contact Group (ECG) responded to the AMLA consultation on draft Regulatory Technical Standards (RTS) on group-wide AML/CFT requirements.  These requirements aim to clarify how EU-wide anti money laundering and counter terrorist financing requirements should be applied across cross border groups, including subsidiaries and branches in third countries.

The ECG broadly supports the objective of harmonisation but raises significant concerns about the scope and practicality of the proposals. In its response, the ECG highlights that the draft RTS does not adequately reflect the reality of professional services networks composed of legally independent firms, creating uncertainty around definitions, control, and enforceability.

It cautions that broad criteria - such as shared branding or strategy - risk being treated as proxies for control, potentially imposing group-level obligations where no legal authority exists. The ECG also underlines serious legal and operational challenges, particularly regarding cross-border information sharing, legal privilege, and conflicting third-country laws, and stresses that entities should not be held responsible for requirements they cannot legally fulfil.

Overall, the ECG calls for clearer definitions, better alignment with existing legal structures, and a more proportionate and practicable framework.