AMLR 2027: PEP and UBO Changes Fund Managers Need to Know
Last reviewed: October 2026 | Reading time: 27 minutes
AMLR 2027 is the point at which EU fund managers stop working to national AML rules and start working to one regulation. From 10 July 2027, Regulation (EU) 2024/1624, the EU Anti-Money Laundering Regulation (AMLR), applies directly in every Member State1. For in-scope managers, it changes three things at once: who counts as a politically exposed person (PEP), how ultimate beneficial owners (UBOs) are calculated, and what evidence a due diligence file must hold.
The practical problem is that a file can look complete under current rules and still fail the AMLR. A screening rule set to “more than 25%” misses an investor at exactly 25%. A review that stops at the first holding company misses the person who owns enough through two chains. A clean PEP screen says nothing about a minister’s sibling who now counts as a family member.
Fund structures make this harder. Ownership runs through feeder funds, family-office holding companies, co-investment SPVs and nominee arrangements, and control often sits in limited partnership agreements and side letters rather than in a share register. This guide sets out what the AMLR requires, where existing processes fall short, and a practical plan for the months before the application date.
Quick Answer
The EU AMLR is Regulation (EU) 2024/1624, a single AML rulebook that applies directly across the EU from 10 July 2027. For fund managers in scope, it widens the PEP definition, sets beneficial ownership at 25% or more with a separate control test for every person, and requires documented evidence behind each PEP and UBO decision.
Key Takeaways
- The AMLR applies directly from 10 July 2027 to in-scope alternative investment fund managers and other collective investment undertakings, with no national transposition.1
- A beneficial owner holds 25% or more of the ownership interest, so an indirect holder at exactly 25% now counts, while the UK test remains more than 25%.16
- Control through other means, such as board appointment rights or vetoes, must be tested in parallel with ownership for every person in the structure.1
- Heads of regional and local authorities with at least 50,000 inhabitants are PEPs, and siblings count as family members only for heads of state, heads of government and ministers.1
- AMLA submitted its final draft standards on customer due diligence to the European Commission on 1 October 2026, with a proposed six-month transitional period after adoption.34
- Firms must report beneficial ownership register discrepancies within 14 calendar days and keep applying PEP measures for at least 12 months after a person leaves office.1
What does the AMLR change for fund managers in 2027?
The AMLR replaces national implementations of the EU AML Directives with one directly applicable rulebook for customer due diligence, PEPs, beneficial ownership and internal controls. For fund managers, the material changes are a wider PEP definition, a stricter and dual beneficial ownership test, and a higher evidence standard for every decision.
The AMLR sits beside two other instruments. Directive (EU) 2024/1640 (AMLD6) governs national supervisors, financial intelligence units and beneficial ownership registers2. The Anti-Money Laundering Authority (AMLA), based in Frankfurt, writes the technical standards and begins direct supervision of selected obliged entities in 20285.
Because the AMLR is a regulation, the core rules read the same in Luxembourg, Ireland, France and the Netherlands. That removes the comfort of local variations a group may have relied on. The risk for a fund manager is regulatory and commercial: an AMLR-scope file that misses a beneficial owner or a PEP family link is a compliance failure, and the same gap in a co-investor or portfolio company becomes a reputational one.
AMLR timeline for fund managers
| Date | What happens | Relevance to fund managers |
|---|---|---|
| 10 July 20261 | Deadline for AMLA to submit its first draft regulatory technical standards (RTS) to the Commission | The detailed customer due diligence rules move from principle to text |
| 1 October 20263 | AMLA announces final draft RTS on customer due diligence (Article 28(1)), business relationships (Article 19(9)) and group-wide requirements (Articles 16(4) and 17(3)) | The information you must collect is visible in near-final form |
| 10 July 20271 | AMLR applies; AMLA guidelines due on valuing customer assets for the EUR 50 million wealth test | Policies, screening logic and ownership calculations must reflect the AMLR |
| 20285 | AMLA starts direct supervision of selected obliged entities | Large cross-border groups may face EU-level supervision |
| 10 July 20291 | Commission assessment of lower ownership thresholds for higher-risk entity categories | A threshold below 25% could follow for some corporate entities |
Why do current PEP and UBO checks fall short of the AMLR?
Most current processes were built for national rules and list screening: a name check, a register extract and a single ownership threshold. The AMLR tests ownership and control in parallel, counts holdings through every layer, widens PEP relationships and expects the file to show why each conclusion was reached.
A screening result answers a narrow question: does this name match a list entry. It does not establish who owns the investor, who controls it, or whether a family member of a minister sits two layers up the structure. Those are investigative questions, and the AMLR makes them part of the obligation.
| Common current practice | What the AMLR requires | Resulting gap |
|---|---|---|
| Ownership flag at more than 25% | 25% or more of shares, voting rights or other ownership interest1 | Holders at exactly 25% are missed |
| Review stops at the immediate shareholder | All shareholdings at every level are taken into account | Indirect owners and aggregated chains are missed |
| Control checked only when nobody reaches the threshold | Control through other means is assessed in parallel with ownership | Minority holders with board rights or vetoes are missed |
| Register extract treated as verification | Firms cannot rely only on central register data and must report discrepancies | Unverified owners and unreported discrepancies |
| PEP check on the named individual only | Family members and close associates defined in Article 2(1)(35) and (36) | Relatives and business associates are missed |
| Former PEPs declassified on a fixed date | At least 12 months, then until the person no longer poses PEP-related risk1 | Premature declassification |
Which fund managers are in scope of the AMLR?
The AMLR covers alternative investment fund managers and collective investment undertakings that fall within its definition of financial institutions, which refers to the scope of Article 2 of the AIFM Directive (2011/61/EU). Scope depends on the legal entity, its authorization and the activity it performs.
Article 3 of the AMLR lists the obliged entities1. Fund groups usually contain several kinds of entity, and only some carry AMLR obligations directly. Use the table as the starting point for a scope memo, then confirm each conclusion with counsel.
| Entity type | Likely AMLR position | What to confirm |
|---|---|---|
| EU-authorized AIFM managing EU funds | Usually in scope as a financial institution | Which group entity onboards investors and who approves high-risk relationships |
| Self-managed fund or collective investment undertaking marketing its own units | Usually in scope | Whether the fund or its manager performs investor due diligence |
| Non-EU manager marketing into the EU through national private placement | Depends on national rules and EU-based activities | Legal advice for each marketing jurisdiction |
| UK or US manager with no EU entity | Outside the AMLR directly | EU administrators, depositaries and co-investors may still request AMLR-standard information |
| Fund administrator or transfer agent performing onboarding | Often an obliged entity in its own right | Reliance and outsourcing terms; the fund manager keeps responsibility for its own obligations |
Two jobs, one method
Regulatory customer due diligence covers the investors and counterparties a fund manager does business with. Investment due diligence covers targets, founders, management teams and co-investors before capital is committed. The AMLR governs the first. The methods it requires, PEP relationship mapping and ownership tracing, are the same ones deal teams need for private equity and venture capital due diligence.
What has AMLA published on customer due diligence?
On 1 October 2026, AMLA announced final draft regulatory technical standards on customer due diligence under Article 28(1) of the AMLR and submitted them to the European Commission3. They specify the information firms must collect for standard, simplified and enhanced due diligence, and they become binding only after Commission adoption.
AMLA finalized three sets of standards together: customer due diligence, criteria for business relationships and occasional or linked transactions, and group-wide requirements3. Three points matter for fund managers now.
Timing is not yet fixed
The Commission must adopt the RTS and publish them in the Official Journal. AMLA has proposed a six-month transitional period after entry into force, according to Luxembourg’s regulator, the CSSF4.
Existing files need remediation
Information on existing business relationships must be brought into line on a risk-sensitive basis, within the refresh periods in AMLR Article 26(2): at least once a year for higher-risk customers and at least every five years for others1.
Registers identify; verification needs more
The AMLR keeps the EU rule that firms cannot rely only on a central beneficial ownership register to verify an owner, and Article 24 requires discrepancies to be reported within 14 calendar days1.
Register coverage is also thinner in places fund managers deal with. FinCEN’s final rule published on 14 August 2026 made permanent the March 2025 exemptions for US companies and US persons from Corporate Transparency Act reporting1112. For US-formed investors or holding companies, there is no federal register entry to compare against, so the firm’s own ownership verification carries more weight.
Test your screening against the AMLR before July 2027
Run an AMLR gap review on a sample of high-risk investor and counterparty files to test threshold logic, aggregation across chains, control rights and PEP relationship coverage before July 2027.
How does the AMLR define a politically exposed person?
Under Article 2(1)(34) of the AMLR, a politically exposed person is a natural person who is or has been entrusted with a prominent public function at Member State, EU, international organization or third-country level1. PEP status is a risk indicator, not evidence of wrongdoing.
| Category | Examples of roles covered |
|---|---|
| Executive | Heads of state, heads of government, ministers, deputy or assistant ministers |
| Legislative and political | Members of parliament or similar legislative bodies; members of governing bodies of political parties, including specified regional and local roles |
| Judicial and audit | Members of supreme and constitutional courts and other high-level judicial bodies; members of courts of auditors |
| Central banks and state enterprises | Members of central bank boards; members of the administrative, management or supervisory bodies of state-owned enterprises |
| Diplomatic and military | Ambassadors, chargés d’affaires and high-ranking officers in the armed forces |
| International organizations | Directors, deputy directors and board members, or equivalent functions |
| Regional and local | Heads of regional and local authorities, including groupings of municipalities and metropolitan regions, with at least 50,000 inhabitants1 |
Regional and local officials
The 50,000-inhabitant threshold brings mayors and regional leaders of mid-sized cities into scope. Member States can set a lower threshold where risk justifies it, so groups with investors in several countries need each national position. Article 43 requires each Member State to publish its list of prominent public functions; the Commission assembles a single EU list, which AMLA publishes1.
Family members and close associates
Family members (Article 2(1)(35))
Spouse or equivalent partner, children and their spouses or partners, and parents. Siblings are included only for heads of state, heads of government, ministers and deputy or assistant ministers, unless a Member State extends coverage.
Close associates (Article 2(1)(36))
People with joint beneficial ownership of an entity with a PEP, other close business relationships with a PEP, or sole beneficial ownership of an entity set up for a PEP’s de facto benefit.
Former PEPs (Article 45)
Measures continue for at least 12 months after the person leaves office, then until the firm assesses that the person no longer poses PEP-related risk.
Practitioners often group PEPs as domestic, foreign and international organization PEPs, following FATF terminology. The AMLR applies the same Article 42 measures to PEP relationships whatever the person’s country. UK rules differ: they start from a lower-risk position for domestic PEPs where no other risk factors are present78. A name-only screen cannot find close associates; relationship mapping can, as the Neotas case study on finding undisclosed political links shows.
What enhanced due diligence does the AMLR require for PEPs?
Article 42 requires three measures for PEP business relationships and relevant occasional transactions: senior management approval before establishing or continuing the relationship, adequate measures to establish source of wealth and source of funds, and enhanced ongoing monitoring1. Article 46 extends relevant measures to family members and known close associates.
Article 34 sets the wider enhanced due diligence framework. Article 34(5) adds mandatory measures for higher-risk relationships where a financial institution handles at least EUR 5 million through personalized services for a customer holding total assets of at least EUR 50 million, excluding their private residence1. That can apply to managers offering segregated mandates or bespoke structures to family offices and very wealthy individuals.
Source of wealth vs source of funds
| Source of wealth | Source of funds | |
|---|---|---|
| Question it answers | How did this person build their total net worth? | Where did the money for this subscription or transaction come from? |
| Typical evidence | Career history, business sale agreements, inheritance records, audited accounts, property records, credible public reporting | Bank statements, sale completion statements, dividend records, loan agreements tied to the transfer |
| Common gap | A one-line declaration with no corroboration | Funds arriving from an account or entity not named in the file |
| What the reviewer records | Whether the narrative is plausible against public information and known activity | Whether the transfer path matches the declared source |
What a defensible PEP file contains
Identity resolution
Evidence that the screening match is the same person, using date of birth, nationality and other identifiers.
Role confirmation
The exact function, jurisdiction, start and end dates, and the Article 2(1)(34) category.
Relationship map
Family members and close associates, with the source for each link.
Wealth and funds assessment
A written narrative, the evidence reviewed and the analyst’s view on plausibility.
Adverse media and litigation review
Findings separated into verified facts, allegations and false matches. See adverse media screening.
Senior management approval
Who approved, when, on what information and with what conditions.
Monitoring triggers
The events that reopen the file: a new public role, an ownership change, sanctions exposure or credible new allegations.
How does the AMLR test ownership and control?
Under Article 51 of the AMLR, the beneficial owners of a corporate entity are the natural persons who hold a direct or indirect ownership interest of 25% or more, and the natural persons who control it through other means1. Both tests run in parallel, so a person can be a beneficial owner with a small shareholding or none.
Article 52 defines an ownership interest as 25% or more of shares, voting rights or other ownership interests, including rights to a share of profit, internal resources or liquidation balance, counted at every level of ownership1. A person holding exactly 25% is a beneficial owner under the AMLR. Under regulation 5 of the UK Money Laundering Regulations 2017, the same person does not meet the ownership limb, which uses more than 25%6.
Control signals to review
Article 53 covers control that does not depend on the size of a holding. In private markets, these rights usually sit in governing documents rather than on a share register.
Board appointment rights
The right to appoint or remove a majority of directors or managers.
Veto and reserved matters
Vetoes over budgets, strategy, senior hires, distributions or exits.
Voting agreements
Shareholder or investor agreements that pool or direct votes.
Nominee arrangements
Shares or interests held on behalf of an undisclosed person.
LPA terms and side letters
Advisory committee rights, key-person provisions and bespoke consent rights.
Informal influence
Relationships that give decisive influence, including family links to a PEP or an owner.
Where no beneficial owner can be identified after exhausting the available means, the firm records the senior managing officials and the steps it took. The Commission can also set a lower ownership threshold for higher-risk categories of corporate entity, at a maximum of 15% unless a higher figure below 25% is justified, with its assessment due by 10 July 20291. Build the threshold as a configurable value per entity category. For background on the concept, see the Neotas guide to ultimate beneficial owner meaning and checks.
How do you calculate indirect beneficial ownership under the AMLR?
Multiply the percentages held at each layer of every ownership chain, then add the results for the same person across all chains. If the total reaches 25% or more, that person is a beneficial owner through ownership interest, and the control test still runs separately.
Map every chain
Trace each path from the customer entity to natural persons, including holding companies, partnerships, trusts, nominees and feeder vehicles.
Multiply along each chain
Multiply the percentage held at each layer to get the effective interest through that chain.
Add across chains
Sum each person’s effective interests from every chain, plus any direct holding.
Compare with 25% inclusive
A total of exactly 25.00% meets the test. Check whether a lower category threshold applies.
Run the control test for everyone
Review appointment rights, vetoes, voting agreements and nominee arrangements for every person, whatever their percentage.
Verify against independent records
Compare declarations with company filings, registers and other reliable sources, and report register discrepancies within 14 calendar days1.
Record the working
Keep the structure chart, calculation, sources, date and reviewer in the file.
Example 1: the exact 25% holder
Anna owns 50% of HoldCo A, which owns 50% of the investing entity. Her indirect interest is 50% × 50% = 25%. Under the AMLR, Anna is a beneficial owner. A screening rule still set to “greater than 25%” misses her.
Example 2: two chains that add up
Ben owns 60% of HoldCo B, which owns 30% of a portfolio company: 60% × 30% = 18%. He also holds 8% directly. No single holding reaches 25%, but 18% + 8% = 26%. Ben is a beneficial owner.
Example 3: control without the shares
Clara owns 10% of a co-investment vehicle. A shareholders’ agreement lets her appoint three of five directors and veto the annual budget. Her ownership is well below 25%, but those rights give her control through other means. Clara is a beneficial owner.
| Person | Calculation | Total ownership | Control by other means | Beneficial owner |
|---|---|---|---|---|
| Anna | 50% × 50% | 25% | No | Yes, ownership |
| Ben | (60% × 30%) + 8% | 26% | No | Yes, ownership |
| Clara | 10% direct | 10% | Board majority appointment and budget veto | Yes, control |
The AMLR contains specific provisions for certain legal forms and arrangements, including trusts and similar legal arrangements. Have counsel confirm the calculation rules for any structure that is not a simple corporate chain.
What do the PEP and UBO changes mean for PE, VC and fund structures?
The AMLR changes hit hardest where ownership runs through several vehicles: corporate and family-office investors, feeder funds, co-investment SPVs and nominee arrangements. Each needs indirect ownership calculated through every layer and a control review of the governing documents.
| Structure | Where the risk sits | What to collect |
|---|---|---|
| Corporate and family-office investors | Multi-jurisdiction holding chains; PEP family links | Full structure chart, ownership percentages at each layer, family relationship checks |
| Feeder funds | Look-through to underlying investors | A documented look-through position and the information the feeder’s operator provides |
| Co-investment SPVs | Minority investors with board seats or vetoes | LPA, side letters, shareholders’ agreement alongside the cap table |
| Portfolio companies and targets | PEP-linked or nominee-held stakes create bribery, sanctions and reputational exposure | Ownership tracing, PEP mapping and adverse media before signing |
| Outsourced onboarding | Administrator files accepted without review | Reliance terms, oversight records and escalation route to the MLRO |
Pre-investment diligence on a target is a commercial and reputational exercise rather than AMLR customer due diligence on the fund’s investors. The methods are the same, which is why many firms run one ownership and PEP workflow for both, supported by an investment due diligence checklist. The AMLR permits reliance and outsourcing under conditions, but the fund manager remains responsible for meeting its own obligations.
How should fund managers prepare for the AMLR before July 2027?
Confirm scope entity by entity, map current PEP and beneficial ownership rules against the AMLR, recalculate ownership in the highest-risk files, and remediate gaps in order of risk before 10 July 2027. Every step should leave written evidence.
Write the scope memo
List every fund, manager and service entity, state whether each is an obliged entity, and record the legal basis.
Read the AMLA final draft RTS
Compare the information requirements with what your onboarding forms collect today.
Rebuild the PEP taxonomy
Map categories to Article 2(1)(34), add the 50,000-inhabitant local tier and any lower national thresholds.
Fix family and associate rules
Apply Article 2(1)(35) and (36), including siblings only for the specified senior roles unless national rules go further.
Change the threshold to 25% or more
Update screening rules, calculation tools and templates, and make the threshold configurable.
Add aggregation and the parallel control test
Multiply along chains, add across chains and review control rights for every person.
Set the verification standard
Define the independent sources that verify owners, how discrepancies are resolved, and how Article 24 reports are made within 14 days.
Rewrite PEP and EDD procedures
Cover senior management approval, source of wealth and funds, the Article 34(5) wealth test and the Article 45 former-PEP assessment.
Test a sample of live files
Re-run high-risk investor and counterparty files and record new beneficial owners, reclassified PEPs and missing evidence.
Fund the remediation plan
Assign owners and dates to each gap, schedule refreshes within Article 26(2) periods, and report progress to the board.
Suggested timeline to 10 July 2027
| Period | Focus | Output |
|---|---|---|
| Q4 2026 | Scope and gap analysis against the AMLR and AMLA final draft RTS | Signed scope memo and gap register |
| Q1 2027 | PEP taxonomy, ownership calculation logic, policy and procedure drafts | Updated policies, screening rules and templates |
| Q2 2027 | File sampling, remediation of the highest-risk files, staff training | Test results, remediated files, training records |
| 10 July 2027 | AMLR applies | Board sign-off on readiness |
| After RTS adoption | Transitional period and risk-based refresh of remaining files | Refresh completed within Article 26(2) periods |
Find the ownership, control and PEP gaps in your high-risk files
Neotas analysts can trace multi-layer ownership, review control rights in governing documents and map PEP family and associate links for the files your gap review flags.
Why does ongoing monitoring matter after onboarding or closing?
Ongoing monitoring matters because AMLR obligations continue for the life of the relationship. Article 42 requires enhanced ongoing monitoring of PEP relationships, and Article 26(2) sets outer limits for refreshing customer information: at least annually for higher-risk customers and at least every five years for others1.
Ownership, control and political exposure change after closing. A family office restructures, a co-investor sells a stake, an investor’s relative takes a ministerial post. A file that was accurate on day one can be wrong by the next capital call.
Ownership changes
Transfers, new holding layers or nominee arrangements in an investor or co-investor.
New public roles
Appointments that create PEP status for an owner or a family member.
Sanctions exposure
New designations affecting an owner, director or related party.
Credible adverse media
New allegations, litigation or regulatory action involving the relationship.
Monitoring after close is where automation earns its place: structured screening across connected data sources, with alerts routed to analysts who decide what each change means. The Neotas approach to perpetual due diligence for fund managers covers this in more detail.
What are the most common AMLR mistakes fund managers make?
The most common AMLR mistakes sit in screening logic and calculation templates rather than in policy wording, which is why they survive policy reviews.
High-risk mistake
Leaving the ownership threshold at “more than 25%”. Rules inherited from earlier national law or UK group policy miss every beneficial owner at exactly 25%, which the AMLR captures16.
| Mistake | Why it fails under the AMLR | Fix |
|---|---|---|
| Checking only the immediate shareholder | All levels of ownership count, and chains are added together | Multiply along chains and aggregate per person |
| Running the control test only when nobody reaches 25% | Article 51 requires both tests in parallel | Review control rights for every person |
| Declassifying former PEPs at month 12 | Article 45 sets 12 months as a minimum | Record a risk assessment before declassifying |
| Treating a no-hit screen or register extract as proof | A clean screen can reflect a spelling variant or missing source; registers alone do not verify | Verify with independent records and resolve discrepancies |
| Screening only at onboarding | Enhanced ongoing monitoring applies to PEP relationships | Set monitoring triggers and refresh periods |
| Assuming outsourcing moves the obligation | The fund manager keeps responsibility | Document oversight and escalation |
| No audit trail | Decisions must be explained to supervisors | Retain sources, calculations, approvals and dates |
How does the EU AMLR compare with UK and US requirements?
The EU AMLR, the UK Money Laundering Regulations 2017 and US Bank Secrecy Act rules are separate regimes. The AMLR uses a 25%-or-more ownership test, the UK uses more than 25%, and the US FinCEN Customer Due Diligence (CDD) Rule uses 25% or more plus a single control person169.
| Area | European Union | United Kingdom | United States |
|---|---|---|---|
| Main framework | AMLR, with AMLD6 and AMLA standards12 | Money Laundering Regulations 2017 and FCA guidance | Bank Secrecy Act and FinCEN rules, including the CDD Rule |
| PEP treatment | Article 42 measures apply to PEP relationships regardless of nationality | Regulation 35 and FCA FG25/3; domestic PEPs start from a lower-risk position absent other factors78 | Risk-based AML programs and examination guidance |
| Ownership threshold | 25% or more (Article 52)1 | More than 25% (regulation 5)6 | 25% or more (ownership prong)9 |
| Control test | Control through other means, assessed in parallel for every person | Ultimate control over management alongside the ownership limb | One individual with significant responsibility to control, manage or direct the entity |
| Beneficial ownership reporting | National central registers; obliged entities report discrepancies within 14 calendar days | Companies House persons with significant control register | CTA reporting narrowed by the final rule published 14 August 2026; US companies and US persons exempt11 |
| Key dates | AMLR applies 10 July 20271 | Domestic framework continues | Investment adviser AML/CFT program and SAR rule effective 1 January 202810 |
The FinCEN Corporate Transparency Act change affects what companies report to FinCEN. It does not remove a covered financial institution’s own customer due diligence duties. For a wider comparison, see enhanced due diligence requirements in the UK, US and EU.
How should you evaluate a PEP and UBO screening and intelligence process?
Evaluate a screening and intelligence process by testing it against the cases the AMLR is designed to catch: the exact 25% holder, aggregated chains, control without shares, PEP family links and register discrepancies. A process that handles only name matching will not pass.
| Criterion | What good looks like | Question to put to your provider or team |
|---|---|---|
| Threshold logic | 25% or more, configurable per entity category | Can the threshold be changed without rebuilding the workflow |
| Ownership aggregation | Multiplication through layers and aggregation across chains | Show the calculation for a two-chain owner |
| Control review | Governing documents reviewed for appointment rights, vetoes and nominees | Who reads the LPA and side letters, and where is that recorded |
| PEP coverage | AMLR categories, local tier, family and associates, multilingual name matching | How are siblings handled by role, and in which languages |
| Verification and discrepancies | Independent sources beyond the central register; 14-day reporting workflow | Which sources verify an owner, and who files the report |
| Analyst investigation | Escalation from alerts to analyst-led research and OSINT | What happens when screening cannot resolve a structure |
| Monitoring | Continuous screening with defined triggers and alerting | Which events reopen a file automatically |
| Audit trail | Sources, calculations, approvals and dates retained | Can a supervisor follow the reasoning on any file |
How does Neotas support AMLR PEP and UBO due diligence?
Neotas combines structured screening with analyst-led intelligence: automate what you can, investigate what you must. Screening handles volume and monitoring; analysts resolve the ownership structures, control rights and PEP relationships that screening cannot.
Structured screening
PEP, sanctions and adverse media screening with configurable risk models and alerting.
Beneficial ownership investigation
Multi-layer ownership tracing and control review for structures that registers and declarations do not resolve.
OSINT and social media intelligence
Open-source research across 30+ languages through the OSINT investigation platform.
Enhanced due diligence
Analyst-led enhanced due diligence for PEPs, source of wealth and higher-risk relationships.
Continuous monitoring
Ongoing screening across connected data sources, with alerts routed for review.
Full audit trail
A record of what was checked, when, by whom and what was concluded.
Neotas supports the firm’s own process; the obliged entity keeps responsibility for its decisions. The case study on OSINT for source of wealth checks shows how independent research builds the evidence base for a higher-risk assessment.
Prepare your fund for AMLR with screening and analyst-led intelligence
Speak with Neotas about investor files, co-investors and counterparties where ownership, control or political exposure is unclear, and how structured screening plus enhanced due diligence closes those gaps before July 2027.
Related Reading
Perpetual Due Diligence for Fund Managers
How fund managers keep investor, UBO and PEP information current between periodic reviews.
Investment Due Diligence for Private Equity and Venture Capital
Pre-investment checks on targets, founders and co-investors, including ownership tracing and PEP screening.
Ultimate Beneficial Owner (UBO): Meaning and Checks
The UBO concept, ownership calculations and how declarations are collected and checked.
Enhanced Due Diligence Requirements: UK vs US vs EU
When enhanced due diligence applies in each jurisdiction and how PEP and ownership rules differ.
Case Study: Finding Undisclosed Political Links
How PEP screening and investigation surfaced political connections that were not declared.
Customer Due Diligence Requirements
Standard CDD steps from identification to ongoing monitoring, now specified in more detail by AMLA.
Frequently Asked Questions
When does the EU AMLR apply?
Does the AMLR apply to alternative investment fund managers?
What is a politically exposed person under the AMLR?
How do you determine if someone is a PEP?
Are siblings of PEPs family members under the AMLR?
How long does someone remain a PEP after leaving office?
What is the UBO threshold under the AMLR?
Can a person with less than 25% ownership be a UBO?
How do you identify the ultimate beneficial owner of a fund investor?
What is the difference between source of wealth and source of funds?
Do fund managers have to report UBO discrepancies to central registers?
What has AMLA published on customer due diligence?
Should PEP and UBO checks continue after closing?
Does the AMLR apply to UK or US fund managers?
References
- Regulation (EU) 2024/1624 (Anti-Money Laundering Regulation), Official Journal of the EU, EUR-Lex
- Directive (EU) 2024/1640 (AMLD6), Official Journal of the EU, EUR-Lex
- AMLA, press release: AMLA finalises key standards for the private sector, 1 October 2026
- CSSF, communiqué: AMLA adopts key Regulatory Technical Standards, October 2026
- CSSF, communiqué: The new AML/CFT Regulation, the Sixth AML/CFT Directive and the future EU AML/CFT supervisor, June 2024
- UK Money Laundering Regulations 2017, regulation 5, legislation.gov.uk
- UK Money Laundering Regulations 2017, regulation 35, legislation.gov.uk
- Financial Conduct Authority, FG25/3: Treatment of politically exposed persons
- FinCEN, Customer Due Diligence Rule FAQs
- Federal Register, Delaying the effective date of the AML/CFT program and SAR requirements for investment advisers, 2 January 2026
- Federal Register, Beneficial Ownership Information Reporting Requirement Revision, 14 August 2026
- Federal Register, Beneficial Ownership Information Reporting Requirement Revision and Deadline Extension, 26 March 2025
This article is general information and not legal advice. Firms should take advice on how the legislation applies to their own entities, funds and activities, and check the legislation, AMLA standards and regulatory guidance for updates before relying on it.
