One long job can count

Does a one-off job become a client relationship only when the work comes back? AMLA's final draft EU standard adds a second question for lawyers, tax advisers and other service professions: does one service require multiple actions carried out over a substantial period of time?

The document is AMLA's final report of 30 September 2026, Frankfurt am Main: draft regulatory technical standards under Article 19(9) of Regulation (EU) 2024/1624, the AMLR, on criteria for identifying business relationships, occasional transactions and linked transactions as well as lower thresholds, with the text of a draft Commission Delegated Regulation. It is not law. AMLA's press release of 1 October 2026 says the final drafts have been submitted to the European Commission, and AMLA's factsheet says they remain subject to review and potential amendments by the Commission and become definitive only on publication in the Official Journal.

Why the label matters. AMLA's factsheet: in a business relationship, CDD is required and ongoing monitoring applies; for an occasional transaction below the relevant threshold, usually EUR 10 000, CDD is not required unless any of the exceptions in AMLR Article 19 applies. For a firm that provides a service rather than carrying out the transaction, the value of the underlying asset or transaction, not the fee, is what counts.

The new text is draft Article 2(2). Obliged entities as defined in Article 3(3), points (a) to (d) and (l), of the AMLR shall, for the purpose of distinguishing a business relationship from an occasional transaction, at least take into account whether the provision of a service requires multiple actions carried out over a substantial period of time when considering the element of duration included in the definition of a business relationship. In plainer words: for these firms, one matter that takes many steps over a long time is now something they must weigh, even if the client never comes back. The factsheet puts these provisions under providers of services, naming auditors, tax advisers, lawyers and real estate agents among others.

That is the change from February. In the consultation paper of 9 February 2026, the paragraph addressed to the same firms carried only repetition criteria: the provision of services at different intervals, and the provision of different services. Those two remain, now as Article 2(3). AMLA's feedback describes Article 2(2) as a new article and says the two paragraphs are not cumulative: where any one of the elements is present, this is sufficient to establish the existence of a business relationship.

Read that with the limits the text keeps. Article 2(2) says take into account, not conclude. Recital 4 says the criteria are neither exhaustive nor determinative; their fulfilment does not in itself establish, nor their absence preclude, a business relationship. The factsheet adds that repetition or duration are not the sole elements of the definition, and that you should ensure all the elements are met. In plainer words: either duration or repetition can satisfy that part of the definition, but no single criterion decides it.

The new paragraph came out of the professions' own feedback, though not in the direction some asked. AMLA reports that stakeholders argued services connected to a single transaction may involve multiple interactions over an extended period without creating an ongoing business relationship, and that some requested sector-specific exemptions. AMLA's answer: an RTS cannot provide exemptions from Level 1.

The worked examples are gone. February's recital named notaries, lawyers, accountants, trust or company service providers, investment migration operators and tax advisors, and walked through a lawyer managing client money and a client selling one property and buying another in a chain. The final recital 8 keeps only general considerations, which may include whether a service requires a series of actions over time, whether services are provided to the same customer at different intervals, including in relation to different objects, and whether different categories of services are provided. AMLA says an RTS is not the instrument for extensive practical examples, and intends non-binding explanatory material.

Nothing applies yet. Draft Article 4: entry into force on the twentieth day after publication in the Official Journal; application six months after that, except for obliged entities referred to in Article 3, points (3)(n) and (o), of the AMLR, from 10 July 2029; AMLA's press release puts football agents and professional football clubs on that date. February's draft said 10 July 2027.

So, on this draft, the question for a Cyprus law, audit or tax practice is no longer only whether the work comes back. It is also whether one job takes multiple actions over a substantial period of time.

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

Sources

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• CONTEXT.
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