# AMLR Art. 34 — Scope of enhanced due diligence > GwG Art. 8b and 8c (advisers) in force 1 October 2026. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.10 - Customer due diligence|FATF R.10]], [[FATF R.19 - Higher-risk countries|FATF R.19]] - **Swiss provisions:** [[GwG Art. 6 - Special due diligence obligations (clarification|GwG Art. 6]], [[GwG Art. 8b - Adviser CDD- identify client, establish|GwG Art. 8b]], [[GwG Art. 8c - Simplified or enhanced adviser CDD|GwG Art. 8c]], [[GwV-FINMA Art. 13 - Higher-risk business relationships|GwV-FINMA Art. 13]], [[GwV-FINMA Art. 14 - Higher-risk transactions|GwV-FINMA Art. 14]], [[GwV-FINMA Art. 15 - Additional clarifications for higher risks|GwV-FINMA Art. 15]], [[GwV-FINMA Art. 16 - Means of clarification|GwV-FINMA Art. 16]], [[GwV-FINMA Art. 17 - Timing of additional clarifications|GwV-FINMA Art. 17]], [[GwV-FINMA Art. 18 - Entering higher-risk business relationships|GwV-FINMA Art. 18]], [[GwV-FINMA Art. 19 - Senior management responsibility for higher|GwV-FINMA Art. 19]] - **Detailed citation:** GwG Art. 6; Art. 8b Abs. 3, Art. 8c (advisers); GwV-FINMA Art. 13-19 ## What it requires Enhanced due diligence applies in the listed higher-risk cases (Art. 29, 30, 31, 36-46) and wherever else obliged entities identify higher risk under their own assessment. Obliged entities must always examine the origin, destination and purpose of transactions that are complex, unusually large, unusually patterned, or without apparent economic or lawful purpose. For other higher-risk cases, Art. 34(4) lists proportionate measures obliged entities may apply - additional customer, source-of-funds and transaction information, senior-management approval, enhanced monitoring, first-payment channelling - with extra measures for very-high-net-worth relationships under Abs. 5. ## Swiss position GwV-FINMA Art. 13 Abs. 3 makes four categories higher-risk per se: foreign PEPs (Bst. a), their associates (Bst. b), foreign correspondent-bank relationships (Bst. c), and residents of an FATF high-risk/non-cooperative country (Bst. d). Abs. 4 makes domestic PEPs, IGO and sports-federation PEPs, and their associates, higher-risk only with a further risk criterion. Art. 14-17 set transaction-level criteria and the content, means and timing of clarification. Art. 18 requires approval by a superior, superior unit or management to open any higher-risk relationship, without restriction. Art. 19 Abs. 1 Bst. a escalates opening decisions to the top management body for all of Abs. 3 (Bst. a-d) plus Abs. 4 Bst. a-c, but requires annual continuation review only for Abs. 3 Bst. a-b plus Abs. 4 Bst. a-c. GwG Art. 6 sets the statutory basis; for advisers, GwG Art. 8b Abs. 3 requires clarification where high risks justify it, and Art. 8c leaves the circumstances and scope to SRO regulation. ## Key divergences AMLR Art. 34 is an open, factor-based EDD regime fed by Annex III and AMLA guidance (Art. 34(3)). GwV-FINMA Art. 13 instead hard-codes a two-tier structure: relationships higher-risk regardless of any other factor (Abs. 3) versus relationships higher-risk only with a further criterion (Abs. 4) - a distinction AMLR Art. 34 does not draw in the same terms. The general list of higher-risk criteria beyond those fixed categories is left to criteria the intermediary itself develops (Art. 13 Abs. 1-2), and for advisers to SRO regulation under GwG Art. 8c, rather than set by the Annex III factors under Art. 34(3). Continuing a correspondent-banking relationship (Bst. c) or a relationship with an FATF high-risk-country resident (Bst. d) needs no annual top-management review; Abs. 4 Bst. d-e (sports-federation PEPs, associates) get neither escalation nor review. AMLR Art. 34(4)(e) treats senior-management approval as available across all higher-risk cases without a comparable carve-out. ## Effective dates GwG Art. 8b and 8c (advisers) in force 1 October 2026. ## 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.* - [[FATF R.1 - Assessing risks and applying a risk-based approach|FATF R.1 — Assessing risks and applying a risk-based approach]] — R.1 sets the general principle that higher risks need adequate, proportionate measures; AMLR Art. 34 implements it as an enhanced due diligence regime with a measures catalogue. *(related)* - [[GwV-FINMA Art. 5 - Foreign branches and group companies|GwV-FINMA Art. 5]] — Both concern foreign branches and group companies in higher-risk countries but pull in different directions: GwV-FINMA Art. 5 requires them to apply the Swiss principles including special clarifications for higher risks, especially in internationally higher-risk countries; AMLR Art. 34(8) only stops EDD being invoked automatically for EU entities' third-country branches and subsidiaries that fully comply with group-wide policies (Art. 17). *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 34 — English text (EUR-Lex, CELEX 32024R1624) > **Article 34** > *Scope of application of enhanced due diligence measures* > 1. In the cases referred to in Articles 29, 30, 31 and 36 to 46, as well as in other cases of higher risk that are identified by obliged entities pursuant to Article 20(2), second subparagraph, obliged entities shall apply enhanced due diligence measures to manage and mitigate such risks appropriately. > 2. Obliged entities shall examine the origin and destination of funds involved in, and the purpose of, all transactions that fulfil at least one of the following conditions: > (a) the transaction is of a complex nature; > (b) the transaction is unusually large; > (c) the transaction is conducted in an unusual pattern; > (d) the transaction does not have an apparent economic or lawful purpose. > 3. With the exception of the cases covered by Section 2 of this Chapter, when assessing the risks of money laundering and terrorist financing posed by a business relationship or occasional transaction, obliged entities shall take into account at least the factors of potential higher risk set out in Annex III and the guidelines adopted by AMLA pursuant to Article 32, as well as any other indicators of higher risk such as notifications issued by the FIU and findings of the business-wide risk assessment under Article 10. > 4. With the exception of the cases covered by Section 2 of this Chapter, in cases of higher risk as referred to in paragraph 1 of this Article, obliged entities shall apply enhanced due diligence measures, proportionate to the higher risks identified, which may include the following measures: > (a) obtaining additional information on the customer and the beneficial owners; > (b) obtaining additional information on the intended nature of the business relationship; > (c) obtaining additional information on the source of funds, and source of wealth of the customer and of the beneficial owners; > (d) obtaining information on the reasons for the intended or performed transactions and their consistency with the business relationship; > (e) obtaining the approval of senior management for establishing or continuing the business relationship; > (f) conducting enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination; > (g) requiring the first payment to be carried out through an account in the customer’s name with a credit institution subject to customer due diligence standards that are not less robust than those laid down in this Regulation. > 5. Where a business relationship that is identified as having a higher risk involves the handling of assets with a value of at least EUR 5 000 000, or the equivalent in national or foreign currency, through personalised services for a customer holding total assets with a value of at least EUR 50 000 000, or the equivalent in national or foreign currency, whether in financial, investable or real estate assets, or a combination thereof, excluding that customer’s private residence, credit institutions, financial institutions and trust or company service providers shall apply the following enhanced due diligence measures, in addition to any enhanced due diligence measure applied pursuant to paragraph 4: > (a) specific measures including procedures to mitigate risks associated with personalised services and products offered to that customer; > (b) obtaining additional information on that customer’s source of funds; > (c) preventing and managing conflicts of interest between the customer and senior management or employees of the obliged entity that undertake tasks related to that obliged entity’s compliance in relation to that customer. > By 10 July 2027, AMLA shall issue guidelines on the measures to be taken by credit institutions, financial institutions and trust or company service providers to establish whether a customer holds total assets with a value of at least EUR 50 000 000, or the equivalent in national or foreign currency, in financial, investable or real estate assets and how to determine that value. > 6. With the exception of the cases covered by Section 2 of this Chapter, where Member States identify cases of higher risks pursuant to Article 8 of Directive (EU) 2024/1640, including as a result of sectoral risk assessments carried out by the Member States, they may require obliged entities to apply enhanced due diligence measures and, where appropriate, specify those measures. Member States shall notify to the Commission and AMLA their decisions imposing enhanced due diligence requirements upon obliged entities established in their territory within 1 month of their adoption, accompanied by a justification of the money laundering and terrorist financing risks underpinning such decision. > Where the risks identified by Member States pursuant to the first subparagraph are likely to stem from outside the Union and may affect the Union’s financial system, AMLA shall, upon a request from the Commission or on its own initiative, consider updating the guidelines adopted pursuant to Article 32. > 7. The Commission is empowered to adopt delegated acts in accordance with Article 85 to supplement this Regulation where it identifies additional cases of higher risk as referred to in paragraph 1 of this Article that affect the Union as a whole and enhanced due diligence measures that obliged entities are to apply in those cases, taking into account the notifications by Member States pursuant to paragraph 6, first subparagraph, of this Article. > 8. Enhanced due diligence measures shall not be invoked automatically with respect to branches or subsidiaries of obliged entities established in the Union which are located in third countries referred to in Articles 29, 30 and 31 where those branches or subsidiaries fully comply with the group-wide policies, procedures and controls in accordance with Article 17. ## Sources - AMLR Art. 34 — CELEX 32024R1624 - GwG SR 955.0, Art. 6 - GwG (as amended, BBl 2025 2899), Art. 8b - GwG (as amended, BBl 2025 2899), Art. 8c - GwV-FINMA SR 955.033.0, Art. 13 - GwV-FINMA SR 955.033.0, Art. 14 - GwV-FINMA SR 955.033.0, Art. 15 - GwV-FINMA SR 955.033.0, Art. 16 - GwV-FINMA SR 955.033.0, Art. 17 - GwV-FINMA SR 955.033.0, Art. 18 - GwV-FINMA SR 955.033.0, Art. 19