Invest Europe

Response to AMLA Public Consultation on the draft RTS on Customer Due Diligence under Article 28(1) AMLR

Positions & consultation responses

11 May 2026

Invest Europe responded to AMLA’s consultation on draft Regulatory Technical Standards under the AMLR, advocating for a proportionate, risk‑based application of Customer Due Diligence (CDD) to Private Equity, Venture Capital and Infrastructure Fund Management. The response supports AMLA’s objective of harmonisation while calling for clearer operational guidance to reflect closed‑ended fund structures, institutional investor bases and transaction‑driven business models. Invest Europe emphasised the need for simplified due diligence to function effectively in low‑risk contexts, for reliance on functionally equivalent evidence, and for safeguards against national gold‑plating that could undermine proportionality and supervisory convergence.