BetterCo
Whitepaper

From KYC to ReKYC The AMLR 2027 at a glance

The white paper walks through the nine places where the check becomes more demanding, and separates new clients from your existing client base.

What the white paper covers

  • Whether you have to check depends on the individual transaction.
  • The nine places where the same check becomes more demanding.
  • How direct and indirect holdings of beneficial owners are aggregated.
  • Why the source and use of funds belong in every KYC file.
  • Existing clients: one year for high risk, at most up to five years for low risk.
  • What is not yet settled: the drafts of the technical standards.

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  • YPOG
  • Bryan Garnier & Co
  • Arnold
  • KXP Kuehn
  • Lutz | Abel
  • AngelInvest

The summary in seven slides

  1. 1 / 7

    AMLR 2027 affects new and existing customers.

    Start now. But on two different paths.

  2. 2 / 7

    Two paths with two deadlines

    You check new clients under the new rules from July 10, 2027. You update your existing client base on a risk basis.

  3. 3 / 7

    For new clients, the check becomes more extensive.

    These are not new obligations. The same check becomes more demanding in nine places.

  4. 4 / 7

    Three examples from the new KYC file

    The tax identification number, aggregated holdings of beneficial owners and the source of funds.

  5. 5 / 7

    Existing clients follow.

    Whether a KYC file reaches the new standard with little or a lot of effort depends on the quality of the existing data.

  6. 6 / 7

    Updates can be tiered.

    A structured analysis of the existing data shows how much work a file takes.

  7. 7 / 7

    The full concept in the white paper

    Checked against the text of the Regulation, legal status July 2026.

From July 10, 2027

Regulation (EU) 2024/1624 applies directly, with no German implementing act.

New clients

Anyone taking on new clients from July 10, 2027 checks them 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.

The full concept in the white paper