CINOA has submitted its response to the European Anti-Money Laundering Authority (AMLA) consultation on the Draft Guidelines on Business-wide Risk Assessment under Article 10(4) of Regulation (EU) 2024/1624. The Guidelines establish a common framework for obliged entities to identify, assess and document money laundering, terrorist financing and targeted financial sanctions risks across their business operations. 

Deadline to provide feedback: 15 July 2026

Link to the consultation: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-guidelines-business-wide-risk-assessment_en

CINOA welcomes AMLA’s objective of establishing a harmonised framework for business-wide risk assessments and supports the emphasis on a proportionate and risk-based approach. In its submission, CINOA highlights the need for the Guidelines to better reflect the operational realities of non-financial obliged entities, particularly the art and antiques market, where businesses are predominantly micro and small enterprises and risk assessments often rely on qualitative professional judgement rather than quantitative methodologies. 

CINOA’s response calls for greater flexibility in the application of the proportionality principle, clearer guidance for SMEs, recognition of sector-specific sources of information, and practical examples illustrating how the Guidelines should apply in the art market. The submission also encourages AMLA to develop sector-specific guidance to promote consistent implementation while ensuring that compliance requirements remain effective and workable in practice. 

Read CINOA’s full submission here: https://acrobat.adobe.com/id/urn:aaid:sc:EU:e47a2603-d82e-40c9-bf18-0aac93be65a4