Regulatory Impact Log, 28 Sep to 5 Oct 2026: one Medium-impact AML item (EU CDD standards), no FCA, EBA or Consumer Duty items verified in window
Interpretation: the window is 2026-09-28 to 2026-10-05. The EBA's AML standard-setting now sits with the EU's AMLA, so I checked AMLA output as an AML-topic item under the EBA line, and I treated it as relevant on the assumption that the firm has EU operations or EU-facing customers. The FCA website returned 403 to every fetch, so FCA items could not be verified at origin. Rows are impact assessments for you to confirm, not legal advice.
Headline: on 1 October 2026 AMLA finalised three sets of draft EU technical standards, including customer due diligence, and sent them to the European Commission. They are not yet adopted, so no date applies yet.
Impact log
| Published | Regulator/jurisdiction | Item and link | Status | What changed | Effective or comment deadline | Mapped inventory items | Impact | Suggested owner | Action |
|---|---|---|---|---|---|---|---|---|---|
| 2026-10-01 | AMLA (EU), cross-cutting with the EBA AML line | Press Release: AMLA finalises key standards for the private sector | Proposed (final draft RTS submitted to the Commission, not yet adopted) | Three sets of draft RTS were finalised: customer due diligence (information to collect and verify, lower-risk measures, non-face-to-face verification, electronic identification, PEP screening); how to tell business relationships from occasional and linked transactions; and group-wide AML arrangements. Consultation on the CDD and business-relationship drafts ran 9 February to 8 May 2026. | Not stated as a date. Once adopted and published in the Official Journal, proposed to apply six months after entry into force (football agents and clubs: 10 July 2029). | CDD-01 customer due diligence; TM-04 transaction monitoring (linked-transaction criteria); annual AML e-learning; AML policy set (group-wide requirements) | Medium | Retail banking and payments policy owner; CDD-01 control owner; AML training lead | Amend obligation: add the draft RTS to the obligations register as "proposed, not adopted". Redesign or test control: gap-assess CDD-01 against the draft CDD and non-face-to-face verification requirements, and TM-04 against the linked-transaction criteria. Revise training: flag likely onboarding-script changes for front-line staff once adopted. |
Upcoming deadlines
- No dated deadline was stated in any verified in-window item. The AMLA application date depends on Commission adoption and Official Journal publication, which are not yet scheduled.
Checked, no impact
- EBA: the press release list shows no AML or Consumer Duty item from 28 Sep to 5 Oct 2026. The only in-window entry is the 2027 Work Programme (30 Sep 2026), which mentions preparing for the new payment services framework but sets no obligation. Low relevance, no mapped change. Third-party risk guidelines (18 Sep) and the 25 Sep consultation sit before the window and do not touch CDD-01, TM-04 or SAR-02.
- FCA (UK): no in-window AML, CDD, monitoring or SAR item could be verified. Search results suggested several FCA publications around 30 Sep 2026 (a crypto authorisation gateway announcement and other policy documents), but I could not open any of them (403), so none is confirmed or rated. The 2026 FCA items nearest the window are outside it: the money mules multi-firm review, published 23 Sep 2026 (relevant to TM-04 and SAR-02; see Do next).
- Consumer Duty: no new item in window. CP26/23 on scope and proportionality closed for comment on 18 September 2026, with a policy statement expected in Q1 2027; that is a law-firm summary, as the FCA page was blocked. No Consumer Duty publication dated inside the window was confirmed.
Do next
- Confirm whether the firm has EU operations or EU customers, which decides whether the AMLA standards apply to it.
- Log the three draft RTS in the obligations register as proposed, and set a watch for Commission adoption and Official Journal publication.
- Run a gap check of CDD-01 against the AMLA final report on customer due diligence.
- Read the FCA money mules review (23 Sep 2026, just before the window) directly on fca.org.uk and test TM-04 and SAR-02 against it.
- Re-run the FCA checks from a browser session that can open fca.org.uk, then rate the items surfaced in search around 30 Sep.
Coverage
- fca.org.uk pages returned 403 (news search, CP26/23, crypto gateway press release, CP26/32), so no FCA item is verified at origin. EBA and AMLA primary pages were read. EUR-Lex, legislation.gov.uk and court databases were not searched. Law-firm blogs are used only as secondary support.
Sources
- AMLA press release, 1 October 2026: AMLA finalises key standards for the private sector
- Global Regulation Tomorrow, 1 October 2026: AMLA finalises key standards for the private sector
- Global Regulation Tomorrow, 5 October 2026: Monthly cross border AML update
- EBA press releases list (to 30 September 2026)
- EBA press release, 30 September 2026: 2027 Work Programme
- The Compliance Digest (Reed Smith): FCA proposes targeted changes to Consumer Duty