EU law lets five years pass before you recheck who owns a customer.
Blog post from Didit
Article 26 of the EU anti-money laundering regulation, specifically Regulation (EU) 2024/1624, establishes a framework for updating customer information that is both periodic and event-driven, depending on the risk level of the business relationship. The regulation sets maximum intervals for updates at one year for higher-risk customers and five years for lower-risk ones, but these are ceilings rather than prescribed cycles. The periodic reviews must be supplemented by event-driven reviews triggered by changes in customer circumstances, legal obligations regarding beneficial ownership, or awareness of relevant facts. Continuous monitoring is required for transactions, while customer information is governed by these review cycles. The draft guidelines published by the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) emphasize a risk-based approach without specifying fixed frequencies beyond the established limits, and the consultation on these guidelines remains open until 3 September 2026. The regulation highlights the dynamic nature of business verification compared to more static individual identity checks, pointing out that ownership and control details can quickly become outdated, necessitating ongoing vigilance.
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