# AMLR Art. 19 — Application of CDD > GwG Art. 8b has been in force since 1 October 2026. AMLR Art. 19 applies from 10 July 2027. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.10 - Customer due diligence|FATF R.10]] - **Swiss provisions:** [[GwG Art. 3 - Verification of the identity of|GwG Art. 3]], [[GwG Art. 4 - Establishing the beneficial owner|GwG Art. 4]], [[GwG Art. 5 - Repetition of identification - re-establishing|GwG Art. 5]], [[GwG Art. 6 - Special due diligence obligations (clarification|GwG Art. 6]], [[GwG Art. 8b - Adviser CDD- identify client, establish|GwG Art. 8b]], [[GwV-FINMA Art. 44 - Required information|GwV-FINMA Art. 44]], [[VSB 20]] - **Detailed citation:** GwG Art. 3-6; Art. 8b (advisers, new); GwV-FINMA Art. 44 ff. ## What it requires AMLR Art. 19(1) requires customer due diligence whenever a business relationship is established, an occasional transaction reaches EUR 10,000 (crypto-asset service providers: EUR 1,000; cash transactions: at least identification from EUR 3,000), a legal entity or arrangement is created, money-laundering or terrorist-financing is suspected regardless of any threshold, or there are doubts about earlier identification data or about who the customer is. Credit and financial institutions also apply it from EUR 1,000 on fund transfers; gambling providers from EUR 2,000 on winnings or stakes. ## Swiss position GwG builds the same trigger around the 'Aufnahme einer Geschäftsbeziehung' (Art. 3 Abs. 1: identify the contracting party) and 'Kassageschäfte' above a threshold the relevant supervisor sets sector by sector (Art. 3 Abs. 2, 5), plus the beneficial-owner declaration (Art. 4), repeat identification on doubt (Art. 5), and background/purpose clarification for higher-risk or unusual relationships (Art. 6). Advisers instead follow the narrower Art. 8b set - see [[The adviser regime (2025 GwG revision)]]. GwV-FINMA Art. 44 requires the same identification particulars at the start of any business relationship, with no minimum value; [[Scope note — GwV-FINMA Title 5 vs VSB 20]] applies to it. ## Key divergences Only for cash transactions does the GwG use a threshold, set by each supervisor (Art. 3 Abs. 2, 5); opening a relationship has none - unlike AMLR's single EUR 10,000 figure with carve-outs for transfers, crypto and cash. The adviser CDD set under Art. 8b is materially narrower than the full financial-intermediary package AMLR Art. 19 triggers: only client identification, beneficial-owner establishment, documentation, the purpose of the business, and background clarification in high-risk cases - no ongoing-monitoring or re-identification duty. AMLR Art. 19(1)(c) also triggers CDD on the creation of a legal entity or arrangement irrespective of transaction value; for advisers, assisting in forming non-operating legal entities is itself a covered activity (GwG Art. 2 Abs. 3bis Bst. b) triggering Art. 8b; for financial intermediaries the GwG has no separate trigger for that moment. On the ordinance side, GwV-FINMA Art. 44 binds only fintech-licence firms, portfolio managers, trustees and DLT trading systems; for banks the same identification-at-inception duty runs through VSB 20 instead. ## Effective dates GwG Art. 8b has been in force since 1 October 2026. AMLR Art. 19 applies from 10 July 2027. See [[Effective-dates timeline]]. ## Further connections *These links come from an article-by-article comparison of the primary texts. They add to the provisions listed at the top of this note and make no equivalence claim.* - [[VSB 20 Art. 4 - Identifying the contracting partner|VSB 20 Art. 4]] — VSB Art. 4 requires banks to identify the contracting partner when a relationship is opened and for cash transactions above CHF 15,000; AMLR sets EUR 10,000 / EUR 3,000 thresholds. *(direct)* - [[VSB 20 Art. 6 - Identification irrespective of thresholds|VSB 20 Art. 6]] — VSB Art. 6 Abs. 2 requires identification on ML suspicion despite thresholds or exemptions; Abs. 1 captures manifest splitting of amounts, whereas AMLR aggregates all linked transactions. *(direct)* - [[VSB 20 Art. 46 - Repetition in case of doubt|VSB 20 Art. 46]] — VSB Art. 46 Abs. 1 lit. a requires repeating identification where doubts about the contracting partner's identity details persist after clarification; AMLR Art. 19(1)(e) triggers CDD on such doubts. *(direct)* - [[GwV-FINMA Art. 69 - Renewed identification or establishment|GwV-FINMA Art. 69]] — GwV-FINMA Art. 69 requires repeating identification during the relationship when doubts arise about identity details. Binds Title 5 entities only (not banks). *(direct)* - [[GwV-FINMA Art. 51 - Cash transactions|GwV-FINMA Art. 51]] — GwV-FINMA Art. 51 sets identification thresholds for linked cash transactions (CHF 5,000 exchange, CHF 15,000 other); AMLR Art. 19(4) sets EUR 3,000 for at least identification. Title 5 entities only. *(direct)* - [[GwV-FINMA Art. 51a - Virtual currency transactions|GwV-FINMA Art. 51a]] — GwV-FINMA Art. 51a requires identification from CHF 1,000 for single or linked virtual-currency transactions outside a continuing relationship, excluding money transfers; AMLR Art. 19(3)(a) uses EUR 1,000 for CASPs and triggers full CDD, not identification only. Binds Title 5 entities only (not banks). *(direct)* - [[GwV-FINMA Art. 52 - Money and value transfers|GwV-FINMA Art. 52]] — GwV-FINMA Art. 52 requires identification for money and value transfers (always for transfers from Switzerland abroad; for transfers from abroad, the recipient once linked transactions exceed CHF 1,000); AMLR Art. 19(2) triggers CDD at EUR 1,000 for transfers of funds. Binds Title 5 entities only (not banks). *(related)* - [[FATF R.22 - DNFBPs - Customer due diligence|FATF R.22 — DNFBPs: Customer due diligence]] — FATF R.22 extends CDD to casinos (from USD/EUR 3,000) and to professionals preparing company formation; AMLR Art. 19(5) sets EUR 2,000 for gambling, 19(1)(c) covers participation in creating legal entities. *(related)* - [[GwV-FINMA Art. 11 - Waiver of due diligence obligations|GwV-FINMA Art. 11]] — GwV-FINMA Art. 11 Abs. 3 lets the intermediary waive due diligence for non-rechargeable instruments up to CHF 250; AMLR Art. 19(7) lets supervisors exempt non-reloadable e-money up to EUR 150. *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 19 — English text (EUR-Lex, CELEX 32024R1624) > **Article 19** > *Application of customer due diligence measures* > 1. Obliged entities shall apply customer due diligence measures in any of the following circumstances: > (a) when establishing a business relationship; > (b) when carrying out an occasional transaction of a value of at least EUR 10 000, or the equivalent in national currency, whether that transaction is carried out in a single operation or through linked transactions, or a lower value laid down pursuant to paragraph 9; > (c) when participating in the creation of a legal entity, the setting up of a legal arrangement or, for the obliged entities referred to in Article 3, points (3) (a), (b) or (c), in the transfer of ownership of a legal entity, irrespective of the value of the transaction; > (d) when there is a suspicion of money laundering or terrorist financing, regardless of any derogation, exemption or threshold; > (e) when there are doubts about the veracity or adequacy of previously obtained customer identification data; > (f) when there are doubts as to whether the person they interact with is the customer or person authorised to act on behalf of the customer. > 2. In addition to the circumstances referred to in paragraph 1, credit institutions and financial institutions, with the exception of crypto-asset service providers, shall apply customer due diligence measures when initiating or executing an occasional transaction that constitutes a transfer of funds as defined in Article 3, point (9), of Regulation (EU) 2023/1113, that amounts to a value of at least EUR 1 000, or the equivalent in national currency, whether that transaction is carried out in a single operation or through linked transactions. > 3. By way of derogation from paragraph 1, point (b), crypto-asset service providers shall: > (a) apply customer due diligence measures when carrying out an occasional transaction that amounts to a value of at least EUR 1 000, or the equivalent in national currency, whether the transaction is carried out in a single operation or through linked transactions; > (b) apply at least customer due diligence measures referred to in Article 20(1), point (a), when carrying out an occasional transaction where the value is below EUR 1 000, or the equivalent in national currency, whether the transaction is carried out in a single operation or through linked transactions. > 4. By way of derogation from paragraph 1, point (b), obliged entities shall apply at least customer due diligence measures referred to in Article 20(1), point (a), when carrying out an occasional transaction in cash amounting to a value of at least EUR 3 000, or the equivalent in national currency, whether the transaction is carried out in a single operation or through linked transactions. > The first subparagraph of this paragraph shall not apply where Member States have in place, pursuant to Article 80(2) and (3), a limit to large cash payments of EUR 3 000 or less, or the equivalent in national currency, except in the cases covered by paragraph 4, point (b) of that Article. > 5. In addition to the circumstances referred to in paragraph 1, providers of gambling services shall apply customer due diligence measures upon the collection of winnings, the wagering of a stake, or both, when carrying out transactions amounting to at least EUR 2 000 or the equivalent in national currency, whether the transaction is carried out in a single operation or through linked transactions. > 6. For the purposes of this Chapter, obliged entities shall consider as their customers the following persons: > (a) in the case of obliged entities as referred to in Article 3, points (3) (e), (f) and (i) and persons trading in high value goods as referred to in Article 3, point (3) (j), in addition to their direct customer, the supplier of goods; > (b) in the case of notaries, lawyers and other independent legal professionals intermediating a transaction and to the extent that they are the only notary or lawyer or other independent legal professional intermediating that transaction, both parties to the transaction; > (c) in the case of real estate agents, both parties to the transaction; > (d) in relation to payment initiation services carried out by payment initiation service providers, the merchant; > (e) in relation to crowdfunding service providers and crowdfunding intermediaries, the natural or legal person both seeking funding and providing funding through the crowdfunding platform. > 7. Supervisors may, directly or in cooperation with other authorities in that Member State, exempt obliged entities from applying, in full or in part, the customer due diligence measures referred to in Article 20(1), points (a), (b) and (c), with respect to electronic money on the basis of the proven low risk posed by the nature of the product, where all of the following risk-mitigating conditions are met: > (a) the payment instrument is not reloadable, and the amount stored electronically does not exceed EUR 150 or the equivalent in national currency; > (b) the payment instrument is used exclusively to purchase goods or services provided by the issuer, or within a network of service providers; > (c) the payment instrument is not linked to a payment account and it does not permit any stored amount to be exchanged for cash or for crypto-assets; > (d) the issuer carries out sufficient monitoring of the transactions or business relationship to enable the detection of unusual or suspicious transactions. > 8. Providers of gambling services may fulfil their obligation to apply customer due diligence measures referred to in Article 20(1), point (a), by identifying the customer and verifying the customer’s identity upon entry to the casino or other physical gambling premises, provided that they have systems in place that enable them to attribute transactions to specific customers. > 9. By 10 July 2026, AMLA shall develop draft regulatory technical standards and submit them to the Commission for adoption. Those draft regulatory technical standards shall specify: > (a) the obliged entities, sectors or transactions that are associated with higher money laundering and terrorist financing risk and to which a value lower than the value set out in paragraph 1, point (b), applies; > (b) the related occasional transaction values; > (c) the criteria to be taken into account for identifying occasional transactions and business relationships; > (d) the criteria to identify linked transactions. > When developing the draft regulatory technical standards referred to in the first subparagraph, AMLA shall take due account of the inherent levels of risks of the business models of the different types of obliged entities and of the risk assessment at Union level conducted by the Commission pursuant to Article 7 of Directive (EU) 2024/1640. > 10. Power is delegated to the Commission to supplement this Regulation by adopting the regulatory technical standards referred to in paragraph 9 of this Article in accordance with Articles 49 to 52 of Regulation (EU) 2024/1620. ## Sources - AMLR Art. 19 - CELEX 32024R1624 - GwG SR 955.0, Art. 3, 4, 5, 6 - GwG (rev. BBl 2025 2899, in force 1.10.2026), Art. 8b - GwV-FINMA SR 955.033.0, Art. 44