All nationalities
The regulation requires all of a person's nationalities. A single field cannot represent multiple nationality, and it cannot be fixed later without reopening the file.
For notary offices
AMLR 2027 at notary offices
Six questions show what your client files must additionally contain from July 10, 2027.
- about two minutes
- Result right in your browser
- not legal advice
A check by BetterCo, provided by
Your answers are evaluated in your browser. They are only transmitted, together with your contact details, once you request the result.
1 Six questions about your KYC practice
You can answer from memory. The result counts only these six points.
Which clients do you onboard?
Different mandatory data sets apply to individual and corporate clients. This determines which sections you see.
Do you collect the tax identification number?
The regulation requires it “where available”. In Germany, every registered resident has one — and no identification means provides it.
Do you verify the identity of all beneficial owners?
Recording the name alone will no longer be enough. The data set also includes the number of the identity document.
Does your system calculate the next review date based on risk?
High risk annually, all other cases after five years at the latest — per file, not per customer.
Can you say for every field where the value came from?
Electronic identification, register, official document or customer statement — and how it was verified. This is the prerequisite for being able to prove that a gap has been closed at all.
Roughly how many files subject to AML checks do you maintain?
Only used to classify your existing files. A rough estimate is enough.
2 Your interim result after six questions
0
open items
0
partially covered
0
already met
0
not answered
open points in six questions
The full gap check covers further points on private clients, corporate clients and your existing client base. Your answers have been carried over.
Continue with the full checkAddress in separate fields
The attribute list breaks the address down into country, region, town, postal code, street and house number. A free-text field cannot be mapped onto it — so it is also impossible to check which part is missing.
Tax identification number
The tax number must be collected 'where available' — and in Germany it is available for every registered resident. Neither the online ID function nor the wallet's person identification data provides it. That makes it the field that almost always has to be collected separately.
Identity of the person acting
Anyone acting on behalf of another person must not only have their authority checked but must also be identified and verified themselves — with their own data record in the file.
Remote identification needs a justification
The draft technical standards make electronic identification the default for remote onboarding. Video and auto-ident remain permitted, but only as a secondary route — with defined safeguards and the duty to justify to the supervisor why the primary method was not used.
Register evidence in the file
Every new business relationship requires valid proof of registration or a current register extract. Having looked at the register is not enough — the dated evidence belongs in the records.
Calculate ownership through every level
The threshold drops from 'more than 25 percent' to '25 percent or more'. Holdings must be multiplied through every level and parallel chains added up. Reading only the top level misses indirect beneficial owners.
Verify all beneficial owners
From now on, the identity of every beneficial owner must be verified, not just recorded. The data record also includes the identity document number. Reasonable measures are sufficient — not necessarily a video identification per person.
A second source besides the central register
Checking against the transparency register is mandatory. For the verification itself, however, the regulation expressly refers to public registers other than central registers — residence, tax and land registers, information from reputable data providers, confirmations from credit institutions. The transparency register alone does not support the verification.
Ask about nominee arrangements
Names of nominee shareholders and nominee directors are mandatory, including an explicit note of that status. No register provides them — the information has to be requested, documented and checked for plausibility.
LEI, registration number, tax number
Each 'where available' — but where available, mandatory and as a separate field. Adding these details across an existing portfolio afterwards takes considerable effort.
Discrepancy report with a deadline
If your own findings differ from the register entries, this must be reported within 14 calendar days at the latest. Notaries, lawyers, auditors and tax advisers are exempt where the finding stems from assessing a client's legal position or representing them in proceedings.
Date of last update per file
Without this date, no due date can be calculated — and without due dates, no portfolio can be planned. It is the smallest prerequisite for everything else.
Risk-based due dates
At most one year for high risk, at most five years for all other cases — including low risk. These are upper limits. A follow-up list without a link to risk does not reliably meet this.
Source evidence per field
If an identification means does not cover all mandatory attributes, the missing details must be obtained and verified by other means. This can only be proven if, for each field, you store where the value came from and how it was checked — not just at document level.
Justification of the chosen method
Anyone who does not identify electronically in a remote setting must be able to explain why to the supervisor. An optional free-text field will not stand up to that question in an audit.
Document rejected cases
A case that never went ahead is also subject to record-keeping — and, once the retention period ends, to the duty to delete. In practice this is the most frequently overlooked point, because abandoned cases rarely make it into the files.
0 open points in six questions
1 open point in six questions
We see no gap in the points checked. That is rare — and a good starting point for the question of how to prove it to the supervisor.
We found one point that is not covered today, and 0 more that are only partly covered.
We found 0 points that are not covered today, and 0 more that are only partially covered.
You have not answered any questions yet, so the result says nothing about your organization.
Your answers cover the points checked. The partially covered points are still worth a look.
You left 0 questions unanswered — they are counted neither as gaps nor as met.
With around 0 existing files, each of these points affects your entire portfolio, not just new onboardings.
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From July 10, 2027
Regulation (EU) 2024/1624 applies directly, with no German implementing act.
New clients
Clients you take on from July 10, 2027 are checked under the new rules from day one.
Existing clients
Updates are risk-based: one year for high risk, at most up to five years for low risk.