14/10/2026
Common AMLR Gaps We Expect to See in 2027
These are the weaknesses I would bet on finding in a typical gap review. They come from reading the Regulation against how small and mid-size firms usually work, not from any published enforcement data, because the rules have not applied yet.
1. Beneficial owners recorded, not understood
A name and a percentage on a form is not enough. Article 20(1)(b) asks you to understand the ownership and control structure. Articles 51 and 52 add that control can exist independently of shareholding, and that indirect interests are multiplied through the chain. Picture a customer owned 40% by a holding company, which is owned 60% by one individual. That individual holds 24%, below 25%, so the ownership test alone would miss them. The control test might not.
2. A copy-paste risk assessment
Article 10 wants an assessment of your own exposure, taking into account the Annexes, the EU and national risk assessments and your customer base. A template from the internet with your logo on it will not survive a conversation with the supervisor.
3. Governance on paper only
The compliance manager appointed in Article 11 must report to the board at least annually on how the controls work. If no such report exists in board papers, that is a gap.
4. Training that cannot be evidenced
Article 12 expects ongoing programmes that fit each role. Keep dates, content and attendance, and make sure agents and distributors are covered where they do the work.
5. Redacted or missing records
Article 77 says documents, information and records kept under the Article “are not redacted”. Some firms black out ID numbers in stored copies. Check your practice.
6. Unaware of the cash limit
Anyone trading goods or services is caught by the EUR 10,000 cash payment limit (Article 80), whether or not an obliged entity. Retailers and dealers often miss this one.
Fixing them
Start with the files (gap 1), because they take the longest. Then use the readiness checklist to prioritise the rest. The AMLA website is where final guidance will land.
What this means for you
Two or more of these ring true? That is the norm at this stage. Tell us which ones through the enquiry form and we can suggest how big a review you need.
General information, not legal advice.