Print Article

AML/TF & CDD The Risk Factors Guidelines from the EU being updated [DRAFT]


The European Supervisory Authorities (ESAs) issue guidelines on key aspects of the risk-based approach. In June 2017, they published three ESAs issued Guidelines on risk factors and simplified and enhanced customer due diligence (JC 2017 37).

These guidelines set out factors’ firms should consider:

  • When assessing the ML/TF risk associated with a business relationship or occasional transaction.

They also set out how:

  • Firms can adjust the extent of their customer due diligence measures in a way that is commensurate to the ML/TF risks they have identified.

Since then, the applicable legislative framework in the EU has changed, and new risks have emerged and the EU introduces a number of changes that warrant a review of the Risk Factor Guidelines to ensure their ongoing accuracy and relevance:

  • This is the case in particular in relation to the provisions on enhanced customer due diligence related to high-risk third countries.

To support firms’ AML/CFT compliance efforts and enhance the ability of the EU’s financial sector effectively to deter and detect ML/TF, these guidelines have been updated regarding:

  • Business-wide and individual ML/TF risk assessments; - customer due diligence measures including on the beneficial owner;
  • Terrorist financing risk factors; and
  • New guidance on emerging risks, such as the use of innovative solutions for CDD purposes

Read the updated guidelines consultation:

  • Consultation Paper Draft Guidelines under Articles 17 and 18(4) of Directive (EU) 2015/849 on customer due diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions (‘’The Risk Factors Guidelines’’), amending Guidelines JC/2017/37

The Team

Meet the team of industry experts behind Comsure

Find out more

Latest News

Keep up to date with the very latest news from Comsure

Find out more


View our latest imagery from our news and work

Find out more


Think we can help you and your business? Chat to us today

Get In Touch

News Disclaimer

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email