Anti Money Laundering Regulation: Respect the Regulation’s Purpose! Avoid unintended Consequences for Corporates!

The Federal Association of Corporate Lawyers (BUJ), together with several German and European business associations, published a joint position paper on 9 July 2026 concerning the implementation of the EU Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624).

The participating associations strongly support the European Union’s efforts to combat money laundering, terrorist financing and other forms of financial crime. At the same time, the current wording of the AMLR creates legal uncertainties that could result in industrial and commercial companies being subjected to extensive anti-money laundering obligations despite their predominantly non-financial and low-risk business activities. In particular, corporates should not be treated in the same way as financial institutions solely because they control a regulated entity within their group.

The joint position paper therefore calls for a clear, proportionate and risk-based implementation of the Regulation. Interpretative guidance, targeted exemptions and proportionate technical standards are required to ensure that anti-money laundering obligations apply only to genuinely risk-bearing activities and do not unintentionally extend to unregulated or low-risk operations.

Further details and the full joint position paper can be found in the attached document.