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gwg-pflicht.chRecognise risks. Check applicability.

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Possible AMLA applicability: five immediate organisational measures

7. September 2026

A result indicating a possible obligation starts a clarification. Organisations should not wait until a client, bank or authority asks how their process works.

  1. Which activities trigger the review?
  2. Who decides on acceptance and continuation?
  3. Which data and documents must be available?
  4. How are risks escalated and updated?
  5. Which external body or specialist should be involved?

Begin with a structured orientation and record the open points.

Company check (external link)

Turn the first result into a controlled work plan

After a possible positive result, responsibility must not remain between management, client teams and administration. Appoint an accountable person to coordinate facts, prepare decisions and monitor open actions. Separate immediate safeguards from the longer-term operating model.

The first ten working days

  1. Secure facts: record services, mandates, roles and payment paths accurately.
  2. Prioritise risk: address active and complex cases first.
  3. Resolve scope: clarify applicability, supervision and SRO questions.
  4. Control transition: state which new work requires approval while the analysis is open.
  5. Plan implementation: document processes, files, training, controls and dates.

A proper close includes the reasoned legal assessment, approved procedures, trained staff, prioritised legacy files and a date for effectiveness testing. Use the revision guide for timing and the file guide for the operating structure.