The AMLR occasional transaction threshold applied to four illustrative customers under four aggregation windows.
Under the EU Anti-Money Laundering Regulation, customer due diligence is due on an occasional transaction of at least €10,000, whether carried out in a single operation or through linked transactions (Regulation (EU) 2024/1624). In practice you add up each customer's transactions over a look-back window and apply CDD at the transaction that takes the total to €10,000. On an illustrative customer exchanging €4,200, €3,900 and €2,600 over twelve days, a 30-day window triggers CDD on day 12 at €10,700; a 7-day window never triggers, and neither would the old €15,000 threshold on a 30-day look-back.
Worked in full in The EU AML Handbook by Julian R. Sterling, with every figure reproduced in a free workbook.See the book on Amazon →
The AMLR, which applies from 10 July 2027, lowers the occasional transaction threshold from the €15,000 of the Fourth AML Directive to €10,000, and keeps the linked transactions test. It does not turn "linked" into a number of days. The firm has to choose an aggregation rule, apply it consistently, document why it fits its business, and be ready to show a supervisor that it catches splitting. Further technical standards from AMLA may narrow the choice; check the final texts before fixing your rule. The arithmetic below shows why the choice is not a detail.
This threshold is separate from the AMLR's €10,000 cap on cash payments to persons trading in goods or providing services (Article 80), from the much lower trigger for occasional transfers of funds, where CDD applies above €1,000, which is why a money remitter cannot use the arithmetic below, and from the separate test for a business relationship: a customer who keeps coming back may be in a relationship that requires CDD whatever the amounts.
Four illustrative occasional customers of a bureau de change. Amounts are in euro equivalent; day 1 is each customer's first visit.
| Customer | Transactions (day: amount) | Total |
|---|---|---|
| 1, currency exchange | 1: 4,200; 3: 3,900; 12: 2,600; 40: 4,800; 55: 1,500 | 17,000 |
| 2, one large, one small | 1: 9,500; 2: 900 | 10,400 |
| 3, regular 2,000 | 2,000 every ten days from day 1 to day 81 | 18,000 |
| 4, three branches, one day | 1: 3,300 three times; 5: 400 | 10,300 |
For each new transaction, sum the customer's transactions over the last N days including today, and compare with the threshold. CDD applies before or at the transaction that crosses it.
Rolling total on day t = Σ amounts with (t − transaction day) < N
Customer 1, 30-day window, day 12: 4,200 + 3,900 + 2,600 = 10,700 ≥ 10,000: CDD on the third transaction
Customer 1, 7-day window: days 1 and 3 give 8,100; on day 12 only 2,600 is in the window. Never triggers.
Excel, transactions sorted by customer and date: =SUMIFS(C:C,A:A,A2,B:B,">"&B2-30,B:B,"<="&B2)>=10000
The window is the whole decision. Customer 1's largest single transaction is €4,800 and its largest 7-day total €8,100; its largest 30-day total is €10,700 and its 90-day total €17,000.
| Customer | Same day | 7 days | 30 days | 90 days | Old 15,000, 90 days |
|---|---|---|---|---|---|
| 1 | never | never | day 12 (10,700) | day 12 (10,700) | day 40 (15,500) |
| 2 | never | day 2 (10,400) | day 2 (10,400) | day 2 (10,400) | never |
| 3 | never | never | never | day 41 (10,000) | day 71 (16,000) |
| 4 | never | day 5 (10,300) | day 5 (10,300) | day 5 (10,300) | never |
A same-day rule catches none of the four, including customer 4, whose three visits to three branches on one day total €9,900, €100 short. A 7-day rule catches the obvious splits, 2 and 4, but misses customer 1, who spread three exchanges over twelve days. A 30-day rule catches 1, 2 and 4. Only a 90-day rule catches customer 3, whose €2,000 every ten days never exceeds €6,000 in any 30 days but reaches €10,000 on the fifth visit.
Longer windows catch more and cost more: every trigger is a CDD file, with identification, verification, beneficial owner checks where relevant and a source of funds question above your own risk limits. They also generate triggers on customers who are not splitting at all, such as a tourist changing money twice in a month. Three points help set the window:
Customer 3 is the case for the business relationship test rather than for a longer window. Nine visits in 81 days is a pattern with an element of duration, and treating the customer as a relationship, with CDD at the outset, is often the better answer than waiting for a 90-day sum to cross €10,000.
The common mistake is to implement the threshold per transaction and call the linked test "covered by monitoring". The monitoring scenario then alerts after the fact, while the regulation expects CDD at the point the threshold is reached. The second mistake is carrying the €15,000 figure into the new rule set: on these four customers the old threshold, even on a 90-day window, catches only two, and catches customer 1 on day 40 instead of day 12. The threshold change is small in euros and large in files.
Once the files exist they have to be risk-rated; the scoring is worked in how to calculate a customer AML risk score. The companion page has the free workbook and working documents for the book.
€10,000, single or linked, down from €15,000 under the Fourth AML Directive, from 10 July 2027. On an illustrative customer exchanging €4,200, €3,900 and €2,600 over twelve days, a 30-day aggregation triggers CDD on day 12 at €10,700; the old threshold would not have triggered until day 40, at €15,500, on a 90-day window.
The regulation does not fix a number, so the firm documents its own and tests it on its data. In this example a 7-day window catches two of four customers, a 30-day window three and a 90-day window all four, including a customer paying €2,000 every ten days. Longer windows mean more CDD files, so read a sample of what each extra window adds.
They should be aggregated, because splitting across branches is a classic way to stay under the threshold. An illustrative customer making three €3,300 transactions at three branches on one day totals €9,900, €100 short, and is caught on day 5 at €10,300 only if all branches feed one total. The pattern itself may also warrant a suspicious transaction report.
This article is one calculation from The EU AML Handbook. The book takes the same case from first principles to the decision, chapter by chapter, and every figure it prints is a live formula in the free companion workbooks.
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