CINOA has submitted its response to the European Anti-Money Laundering Authority (AMLA) consultation on the Draft Guidelines on Ongoing Monitoring of a Business Relationship under Article 26(5) of Regulation (EU) 2024/1624. The Guidelines set out how obliged entities should keep customer information up to date and monitor transactions and activities as part of their ongoing AML/CFT obligations.

Deadline to provide feedback: 3 September 2026

Link to the consultation: https://ec.europa.eu/eusurvey/runner/eaddcaba-57d5-0f7d-d5e1-f33d815dee5b#page0

CINOA welcomes the Guidelines’ emphasis on a risk-based and proportionate approach, including the recognition that monitoring processes may differ according to the nature, size and complexity of the obliged entity. In its submission, CINOA highlights the importance of ensuring that these principles work in practice for non-financial sectors such as the art and antiques market, which is largely made up of micro and small businesses without dedicated compliance teams or automated monitoring systems.

CINOA’s response calls for greater clarity on what proportionate ongoing monitoring should look like for smaller businesses, including recognition of manual monitoring processes and a risk-based approach to customer reviews and trigger events. It also stresses that a significant proportion of art market transactions are occasional and do not involve an ongoing business relationship, and that continuous or periodic monitoring should therefore not be expected where no ongoing relationship exists.

CINOA also encourages AMLA to provide practical examples relevant to smaller and non-financial obliged entities and to ensure that proportionality is reflected not only in the choice of monitoring tools, but also in the frequency and depth of checks, documentation requirements and supervisory expectations.

Read CINOA’s full submission here: https://acrobat.adobe.com/id/urn:aaid:sc:EU:4b65202d-4e28-4ebb-a7da-d52438af9b9d