EU AML Regulation applies from 10 July 2027
Trust Circle verifies who your client is, sends your KYC questionnaire, scores the risk and asks the client to renew before their answers expire. Built for notaries, law firms and accounting firms preparing for the EU Anti-Money Laundering Regulation.
Clients verify once on their phone with a passport or national ID. No video call.
What AMLR changes
Regulation (EU) 2024/1624 replaces national AML rules with one rulebook that applies directly in every member state. For firms that onboard clients remotely, three provisions change daily work.
Article 22(6) allows two ways to verify a client: an identity document checked against reliable sources, or eIDAS electronic identification at level substantial or high together with qualified trust services.
Article 26(2) caps the time between updates of client information at 1 year for higher-risk clients and 5 years for everyone else.
Article 77 requires you to keep due diligence records, including data obtained through electronic identification, for 5 years after the relationship ends.
How it works
An ID document scan and a liveness check on their phone. 265+ ID documents from 90+ countries are supported.
Open the person in your People directory and send a request. The client consents on a secure page from their email.
Purpose of the relationship, occupation, source of funds, PEP status, sanctions and tax residence. Each answer is scored.
Pick 6, 12, 24 or 36 months. Trust Circle sends the next request 30 days before the answers expire.
AMLR, article by article
| AMLR article | What it asks of you | What Trust Circle does |
|---|---|---|
| 22(1)(a) | Collect names, date and place of birth, nationality and usual residence | Shares the client's verified identity data, ID document picture and biometric picture, with the client's consent. Residence and tax details come from your questionnaire. |
| 22(6)(b) | Verify identity through eIDAS electronic identification and qualified trust services | Identity is verified by ZealiD, a Qualified Trust Service Provider on the EU Trusted List. |
| 20(1)(c), 25 | Understand the purpose and intended nature of the relationship | A questionnaire section on the purpose of the relationship. |
| 20(1)(e) | Understand the client's occupation or business | Occupation and source of funds questions. |
| 20(1)(g) | Find out whether the client is a PEP, a family member or a close associate | PEP questions for all three, with follow-up questions only when the client answers yes. |
| 20(1)(d) | Check for targeted financial sanctions | Sanctions declarations from the client, plus a staff-only section to record your screening provider, lists checked and result. A sanctions answer can be set to stop onboarding. |
| 20(2), 29 | Scale measures to risk, with extra care for high-risk third countries | Points per answer and per country list give Low, Medium, High or Do not proceed, with a recommended action for each level. |
| 26(2) | Update client information at least every 1 year (higher risk) or 5 years | A renewal period per questionnaire, with automatic renewal 30 days before expiry. |
| 77 | Keep due diligence records for 5 years | Every answer stays tied to the exact questionnaire version and the date it was filled in, in a per-person history you can download. |
Article numbers refer to Regulation (EU) 2024/1624. Your firm's AML policy and risk decisions remain your own.
One record per client
Every client in your People directory shows their KYC status, the questionnaire version they answered, the risk level and the date their answers run out. When you publish a new questionnaire version, you can ask everyone who answered the old one to fill it in again.
ZealiD AB has been listed on the EU Trusted List (Sweden) as a Qualified Trust Service Provider since 2019. We are supervised and audited every year.
Straight answer
No tool makes a firm AMLR compliant on its own. Trust Circle handles identification, verification, the questionnaire, scoring, renewal and the record. These parts stay yours.
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.
Trust Circle gives a score and a recommended action. Enhanced due diligence and senior management sign-off on high-risk clients remain your call.
The questionnaire is built for natural persons. Beneficial ownership checks on legal entities follow your own process.
FAQ
From 10 July 2027, under Article 90 of Regulation (EU) 2024/1624. It applies directly in every member state, without a national transposition law.
The client's general identity information, the picture of their ID document and their biometric picture. You can download each one separately or all three together.
Yes. Nothing is shared without the client's consent. You can send a new request later. A request with no answer expires after 30 days.
The Owner, Admins and Users of your business account. External members of your Trust Circles never see it.
Yes. Start from the standard template, the simplified template, a blank form or a copy of an existing one. Edits stay in draft until you publish a new version, and requests already sent keep the version they were sent with.
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.
Business accounts with the KYC add-on.
Case studies
DocuSign
Customer KYC
Days → minutes
to complete remote KYC
DocuSign customers in German finance onboard clients fully remotely by combining a first bank transfer with a ZealiD qualified signature.
DLA Piper
Legal and public tenders
€20 saved
per signature
The Nordic arm signs commercial agreements, company administration and public submissions with qualified signatures across regions.
