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AMLR
AMLR for firms that onboard clients
The EU Anti-Money Laundering Regulation replaces national AML rules on 10 July 2027. It sets how you verify a client, how often you refresh their data and how long you keep the record. Trust Circle covers identity, the KYC questionnaire, renewals and the record, from a provider on the EU Trusted List.
KYC add-on for Professional, €100 a month · Identity verification included, no fee per check
AMLR ART 22, 26(2) AND 77
Key dates
Three dates that matter for your firm
AMLR applies directly in every EU country, with no national transposition law. It replaces the national rules that implemented the AML directives.
Until then, your national AML law applies, and for banks and other financial firms, the EBA guidelines on remote onboarding. KYC and due diligence in Trust Circle →
What AMLR asks
AMLR turns a client file into a running obligation
What AMLR asks of your firm
- Identify the client and verify their identity
Art 20(1)(a), 22 - Understand the purpose of the relationship and the client's occupation
Art 20(1)(c), (e), 25 - Find out whether the client is a PEP, and check for targeted financial sanctions
Art 20(1)(d), (g) - Update client information at least every year for higher-risk clients, and every 5 years for the rest
Art 26(2) - Keep due diligence records for 5 years after the relationship ends, then delete them
Art 77
Two ways to verify a client remotely
An identity document.
A passport or national ID, plus information from reliable and independent sources where relevant. Art 22(6)(a)
Electronic identification.
eID at assurance level substantial or high under eIDAS, with relevant qualified trust services. Art 22(6)(b)
Before and after
What changes on 10 July 2027
AMLR, article by article
Where Trust Circle covers your due diligence steps
Article numbers refer to Regulation (EU) 2024/1624. Your firm's AML policy and risk decisions remain your own.
AMLA's draft rules
What AMLA's draft rules on client checks say
01
eID comes first.
AMLA's final draft of 30 Sep 2026 makes eID and relevant qualified trust services the default way to verify a client remotely.
02
Document and selfie need a reason.
Remote checks with an ID document and a selfie stay allowed as an alternative, but your firm must record why it could not use the default route.
03
It is still a draft.
The European Commission adopts the final rules. They apply six months after they enter into force, so the details can still change.
Where Trust Circle stands: ZealiD is a Qualified Trust Service Provider on the EU Trusted List. We'll publish how Trust Circle maps to the final rules once the Commission adopts them.
eIDAS and eIDAS 2 →What stays with your firm
Live list screening
Sanctions and PEP screening against live lists runs in your screening tool. You record the provider, the lists checked and the result in Trust Circle.
The risk decision
Trust Circle gives a score and a recommended action. AMLR doesn't let you hand over the client's risk profile or the decision to onboard (Art 18(3)).
Company ownership
The questionnaire is built for natural persons. Beneficial ownership checks on legal entities follow your own process.
Trusted by banks, law firms and platforms
Meets German AML rules (GwG)
DocuSign resells ZealiD's qualified signature, with ID document data, to its customers in German finance for remote identification.
Read the case study →We are building a future-proof bank, digital by design… Our business clients can now sign their credit and guarantee documentation digitally with ZealID, a provider of qualified electronic signatures and a partner of ABN AMRO.
Qualified Trust Service Provider
Check us on the EU Trusted List, not on our word
- Listed on the EU Trusted List (Sweden): qualified certificates for electronic signatures, qualified timestamps and remote qualified signature creation
- Supervised by PTS, the Swedish Post and Telecom Authority
- Audited every year by TÜViT
- Identity checks certified against ETSI TS 119 461
- Client consent recorded for every KYC request
- Documents stored in Stockholm, EU
ZealiD AB
QUALIFIED TRUST SERVICE PROVIDER
LISTED SERVICES · SWEDEN
Pricing
KYC in the Professional plan
Professional + KYC add-on
€119.20a month, billed yearly
+ €100 a month for KYC
- Up to 10 users
- 75 QES a month
- KYC questionnaires, risk scoring and automatic renewal
Identity verification is included in every plan, with no fee per check. See all plans →
Get your client files ready before AMLR applies
Verify once, send your questionnaire, and let renewals run on schedule.
Questions about AMLR
When does the AML Regulation apply?
From 10 July 2027, under Article 90 of Regulation (EU) 2024/1624. Football clubs and agents follow on 10 July 2029.
Does AMLR replace our national AML law?
Yes, for the due diligence rules. It applies directly in every EU country, with no national transposition law. Until 10 July 2027, your national law still applies.
How often must we update client information?
At least every year for higher-risk clients and every 5 years for everyone else, under Article 26(2). Trust Circle sends the renewal request 30 days before the answers expire.
How long do we keep due diligence records?
5 years after the relationship ends, then the personal data must be deleted, under Article 77.
Can we verify clients remotely under AMLR?
Yes. Article 22(6) allows an identity document checked against reliable sources, or eID at assurance level substantial or high with relevant qualified trust services. AMLA's draft rules make eID the default route.
Does Trust Circle screen clients against sanctions lists?
Not itself. The client answers sanctions declarations, and your staff record the screening provider, lists checked, match result and reviewer in a section the client never sees.
Can we hand the risk decision to a provider?
No. Under Article 18(3), the client's risk profile and the decision to onboard stay with your firm. Trust Circle gives a score and a recommended action to support that decision.
Which plans include KYC?
The Professional plan, with the KYC add-on at €100 a month. On Enterprise, KYC is part of a custom plan. See plans.
Does identity verification cost extra?
No. It's included in every plan, with no fee per check.