When the work comes back

When does a one-off job become a client relationship? For the professions that provide services rather than move money, lawyers, accountants and tax advisors among them, AMLA's draft EU standard counts repetition in services: when the work comes back, at different intervals or as a different service, that must at least be taken into account when weighing repetition.

The document is a consultation paper published at Frankfurt am Main on 9 February 2026: draft regulatory technical standards under Article 19(9) of Regulation (EU) 2024/1624, the AMLR, on criteria for business relationships, occasional transactions and linked transactions, and on lower thresholds. The consultation ran from 9 February to 8 May 2026 and is closed; AMLA's page says results will follow. Nothing in it is adopted law. AMLA says it will consider the feedback when preparing its submission to the European Commission.

Why it matters. AMLA's page says that for business relationships, customer due diligence is always required, and for occasional transactions only above certain thresholds. The paper puts the general threshold at a value of at least EUR 10 000; the AMLR sets lower ones for specific sectors or transactions, and the draft recalls four situations in which due diligence is required regardless of value.

The draft defines the one-off by what it is not. Its Article 1: an occasional transaction means a transaction or a provision of services connected to a transaction that is not carried out as part of a business relationship. The two are mutually exclusive, and activity outside the scope of the AML/CFT framework cannot be an occasional transaction at all. In plainer words: if the work is in scope and is not a relationship, it is a one-off. There is no third box.

For firms that provide services rather than perform transactions, the recital says they should consider the value of the transaction to which their services are connected, excluding any transaction or service fees. Your fee is not the number.

Now the core. Draft Article 2(2) is addressed to obliged entities as defined in Article 3(3), points (a) to (d) and (l), of the AMLR. When considering the element of repetition in the definition of a business relationship, they shall at least take into account two criteria: the provision of services at different intervals, and the provision of different services. Recital 8 says many of the services provided by, for instance, notaries, lawyers, accountants, trust or company service providers, investment migration operators and tax advisors are not circumscribed; the provision of service occurs at different intervals that point towards an ongoing engagement.

Its examples do the work. A notary or lawyer managing a bank account or client money provides that service at different intervals, which should be considered as pointing towards repetition. The first criterion should also be understood as one service regarding multiple objects: a client selling a property and purchasing another as part of a wider property chain, an engagement characterized by repeated instructions, financial movements, and documents exchanges. By contrast, a real estate agent's services on buying a property can be circumscribed, because, the recital says, the AMLR clarifies that such services start to be relevant for AML/CFT purposes where there is a clear indication that the parties are willing to proceed with the purchase, sale, rental or lease or with taking the necessary preparatory steps; such transactions do not fulfil the criterion of occurring at different intervals. Different services should be understood as different categories of services within the scope of the AML/CFT framework. In plainer words: the same matter with a second property can point towards repetition, and so can a second kind of in-scope work for the same client.

None of this is automatic. The draft says the AMLR definitions should be leading, the mere fulfilment of any criterion does not automatically indicate that the definition of a business relationship is satisfied, the criteria are not conditional or exhaustive, and a business relationship may exist even in the absence of any of them. The criteria set what you must look at, not the answer.

One other criterion applies to every obliged entity: the use of online services through a registration providing ongoing access, for the element of duration. The draft sets no additional lower thresholds at this point in time. Its Article 4 has it apply from 10 July 2027, and from 10 July 2029 for two categories of obliged entities it identifies only by paragraph reference.

So, on this draft, the moment a Cyprus lawyer or accountant has to ask again whether a one-off is still a one-off is when the work comes back: at a different interval, as a different service, or as the next property in the chain.

Not legal advice. Verify against the primary source before acting.

Sources

• PRIMARY.
• CONTEXT.
• CONTEXT.

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