EU Considers Putting Major Corporate Groups Under AML Spotlight

EU officials are examining whether major companies in the trading bloc such as Volkswagen, BMW, and Red Bull could fall within new group-wide AML requirements, despite not being traditional regulated financial businesses, according to AML Intelligence.

The question centers on corporate parents that own subsidiaries subject to AML rules or network structures including multiple obliged entities. Under Article 16 of the EU’s Anti-Money Laundering Regulation, a parent undertaking must oversee a group-wide risk assessment, establish common AML policies and controls, support information sharing, and maintain a compliance function. What remains uncertain is when these responsibilities extend to an otherwise unregulated parent company or franchisor. 

Draft technical standards published by the EU Anti-Money Laundering Authority (AMLA) in April would apply group-wide requirements to some structures outside conventional corporate groups. These may include networks, partnerships, and franchises containing at least two obliged entities under common ownership, management, or compliance control.

The proposal has raised concerns that an otherwise unregulated parent company or franchisor could become responsible for coordinating AML compliance across a network of legally independent businesses when it potentially lacks the authority and systems to do so. 

AMLA closed its consultation in June and is now preparing the final framework. The new EU regulation is scheduled to apply from July 10, 2027.