Regulation (EU) 2024/1624, EUR-Lex
The AML Regulation: due diligence, beneficial owners and records.
EU KYC, for clients from Asia.
From 10 July 2027 the AML Regulation sets one EU rulebook, detailed by AMLA's technical standards and the EBA's remote onboarding guidelines.
For clients in Asia, Fill Easy returns the evidence from Asian registries and identity schemes, with company ownership.
A summary, not legal advice: the official text governs, and your compliance team decides what your policies require.
One rulebook from 2027.
The AML Regulation (EU) 2024/1624 applies directly in every member state from 10 July 2027. AMLA, in Frankfurt since 1 July 2025, writes its technical standards and will directly supervise selected institutions from 2028. Until then, national rules under the current directive and EBA guidelines apply.
Hong Kong, Singapore, the UAE and Mainland China are not on the EU's high-risk third countries list. The British Virgin Islands has been since 29 January 2026, bringing enhanced due diligence to structures held through the BVI.
At a glance
- Law
- Regulation (EU) 2024/1624 (AMLR), applies from 10 July 2027
- Beneficial owner
- 25% or more, with indirect holdings multiplied along each chain (Art. 52)
- Records
- Five years after the relationship ends (Art. 77)
- High-risk list
- Hong Kong, Singapore, the UAE and China not listed; the BVI listed since January 2026
- Authorities
AMLAAnti-Money Laundering Authority
EBAEuropean Banking AuthorityNational supervisors apply the rules; AMLA directly supervises selected institutions from 2028.
Choose the rule.
The AML Regulation sets the duties; AMLA and the EBA fill in the detail; the registers and the EU wallet change how they are met. Pick one to see what it asks for, and what Fill Easy supplies.
AMLRThe AML RegulationRegulation (EU) 2024/1624, EUR-Lex (opens in a new tab)Individuals
Identify the customer
All names and surnames, place and full date of birth, nationalities and national identification number, and usual place of residence (Art. 22(1)(a)).
GovVerifyCustomers from Hong Kong, Singapore, the UAE or Mainland China verified by their government's digital identity, where your policy accepts it.Verify: two routes
An identity document or passport, with information from reliable and independent sources where relevant, or electronic identification at eIDAS level substantial or high and qualified trust services (Art. 22(6)). For third-country residents without EU eID, the recitals point to qualified trust services.
GovVerifyCustomers from Hong Kong, Singapore, the UAE or Mainland China verified by their government's digital identity, where your policy accepts it.
Companies
Identify the entity
Legal form and name, registered office and principal place of business, country of creation, legal representatives, registration number, tax number and LEI where available, and nominees (Art. 22(1)(b)). New relationships need valid proof of registration or a recent register excerpt (Art. 23(4)).
CorpVerify · registry searchA recent extract from the company's home registry, with its registration number, officers and filings.Beneficial owners
25% or more, counting all layers (Art. 52). Verify with reasonable measures, including public registers other than the central registers, and also check the EU central registers (Art. 22(7)).
CorpVerify · UBO tracingOwnership traced through each registry to the natural persons at the top, with each layer's jurisdiction and holding.Non-EU companies in higher-risk cases
They register their beneficial owners in the central register of the member state where the relationship starts, and the obliged entity asks for proof before proceeding (Art. 67).
The EU register filing is the customer's; Fill Easy supplies the home-registry records behind it.
Records
- Keep due diligence documents, including information from electronic identification, unredacted for five years after the relationship ends (Art. 77).
- Access to databases and screening services is not outsourcing (recital 47), so a data supplier needs no Art. 18 outsourcing notification.
AMLAThe Anti-Money Laundering AuthorityAMLA consultation on the due diligence standards (opens in a new tab)Individuals
What counts as an identity document
Issued by a state or public authority, with all names, date of birth, expiry date, document number, facial image, signature and security features (draft Art. 6(1)).
The document itself stays with your process; GovVerify adds government-confirmed data alongside it.
Documents in a foreign language
The obliged entity must understand their content (draft Art. 6(4)); no certified translation is required at EU level.
CorpVerify · translation and summaryThe original documents with an English summary and structured data, so the file shows what each says.Remote verification
eIDAS electronic identification or qualified trust services first; remote capture of the identity document only where those are not available, with the choice justified (draft Art. 7).
GovVerifyCustomers from Hong Kong, Singapore, the UAE or Mainland China verified by their government's digital identity, where your policy accepts it.
Companies
Verify beneficial owners
Public registers other than the central registers, reliable national systems, or information from reputable data services providers, among others (draft Art. 10).
CorpVerify · UBO tracingOwnership traced through each registry to the natural persons at the top, with each layer's jurisdiction and holding.Complex structures
Three or more layers plus, for example, an entity registered outside the EU, a trust or nominees make a structure complex, requiring further information such as an organigram (draft Art. 12).
CorpVerify · UBO tracingEach layer with its jurisdiction, legal form and holding, traced to the natural persons at the top.
EBAThe EBA remote onboarding guidelinesEBA/GL/2022/15 (opens in a new tab)Individuals
Digital identity schemes
Institutions may use electronic identification processes regulated, recognised, approved or accepted by the relevant national authorities, after assessing them against the guidelines (para 54). Non-EU government schemes are the institution's risk-based decision.
GovVerifyCustomers from Hong Kong, Singapore, the UAE or Mainland China verified by their government's digital identity, where your policy accepts it.Copies of identity documents
Check security features, tampering, the machine-readable zone and image quality, and use chip data where feasible (paras 33 to 36); match the person with liveness detection (paras 38 to 41).
Document capture and liveness checks stay with your onboarding flow.
Companies
Entity and representative
Confirm the entity is publicly registered where applicable and that the representative may act for it (para 38).
CorpVerify · registry searchThe registry record showing the entity and its officers.
AMLD6Beneficial ownership registers and the EU walletDirective (EU) 2024/1640, EUR-Lex (opens in a new tab)Registers
Central registers
Each member state keeps a central register, including the beneficial owners of non-EU entities under AMLR Art. 67, with discrepancies resolved within 30 working days (Art. 10). Obliged entities get timely access for due diligence (Art. 11), under rules applying from 10 July 2026.
Register checks are yours; Fill Easy supplies the source records to compare them with.
Digital identity
EU Digital Identity Wallet
Banks and financial services that must authenticate customers will have to accept the wallet at the user's request (eIDAS 2, Art. 5f(2)); it is for EU residents.
GovVerifyCustomers from Hong Kong, Singapore, the UAE or Mainland China verified by their government's digital identity, where your policy accepts it.
Read the source
The official text.
AMLA regulatory instruments
The status of each technical standard AMLA is preparing.
EBA/GL/2022/15
Guidelines on the use of remote customer onboarding solutions.
European Commission: high-risk third countries
The current EU list and its amendments.
Questions about EU KYC and AML
Not covered here? Ask our team
Can we rely on the data Fill Easy returns?
Yes, as verification evidence. The AML Regulation lets you verify a customer with an identity document plus information from reliable and independent sources, and verify beneficial owners with public registers other than the EU central registers (Art. 22(6) and (7)). AMLA's draft standards name reputable data services providers as a source for beneficial ownership (draft Art. 10), and access to databases is not outsourcing (recital 47). Fill Easy returns home-registry and government identity data unaltered, with its source and retrieval time. The due diligence decision stays with your firm, and the EU central registers still need checking.
Does Fill Easy make us compliant with EU AML rules?
No. The due diligence duty sits with your firm under EU AML rules, and your policies decide what is enough. Fill Easy supplies the evidence those policies rely on: records from the government or registry source, each showing where and when it was retrieved.
Is using Fill Easy outsourcing under the AMLR?
The AMLR says third-party software, access to databases and screening services are not outsourcing (recital 47). Your firm still makes the due diligence and onboarding decisions.
Do documents from Hong Kong or China need a certified translation?
Not at EU level: AMLA's draft standards ask that you understand the content. Fill Easy returns each document with an English summary. Check whether your national supervisor asks for more.
When does the AML Regulation apply?
From 10 July 2027. Until then, national rules under the current directive and the EBA's guidelines apply.
Are clients from Hong Kong, Singapore, the UAE or China high risk under EU rules?
Those jurisdictions are not on the EU's list of high-risk third countries. The British Virgin Islands has been on it since 29 January 2026, so structures held through the BVI bring enhanced due diligence.
Can we onboard a Hong Kong resident remotely?
Yes. Residents outside the EU have no EU electronic identification, so the route is an identity document with information from reliable and independent sources, or qualified trust services. The EBA lets institutions use identification processes recognised by the relevant national authorities, and whether a non-EU government scheme qualifies is a risk-based decision for your firm.
Do non-EU companies register their beneficial owners in the EU?
In higher-risk cases, yes: a legal entity created outside the EU registers its beneficial owners in the central register of the member state where it starts the relationship, and the obliged entity asks for proof before proceeding (AMLR Art. 67).
What makes an ownership structure complex?
Under AMLA's draft standards, three or more layers plus, for example, an entity registered outside the EU, a trust or nominees. Complex structures need further information, such as an organigram, and Fill Easy traces each layer with its jurisdiction and holding.