Registration in goAML also applies to companies that do not actually carry out ‘high-risk’ activities. Do not miss the deadline of 30 November 2026.

Please note that, subject to a few limited exceptions, the obligation to register arises merely from being authorised to carry out the relevant activity. In the vast majority of cases, it is irrelevant whether the activity is actually carried out.

The Financial Intelligence Unit (“FIU’) expressly states in its methodological guidance that the opposite interpretation (I do not carry out the activity, so I am not a reporting entity) is not in accordance with the law.

You should pay particular attention if, for example, the following activities are listed in the commercial (or trade) register:

• bookkeeping,
• brokering the sale and purchase of property,
• acting as an organisational and economic adviser,
• trading in receivables,
• gambling operator,
• provision of asset management services or services for commercial companies,
• financial leasing or other financial activities,

and other entities as specified in Section 5 of the AML Act.

What are the consequences if an obliged entity fails to register?

For a breach of the registration obligation, the FSJ may impose a fine of up to EUR 1,000,000 or up to twice the amount of the unauthorised gain, whichever is higher.

How should one proceed?

In light of the FSJ’s guidance, we recommend that any business entity authorised to carry out any of the above-mentioned activities register in goAML, regardless of whether it actually carries out such activities.

Businesses that do not carry out these activities and do not intend to do so may align the activities registered in the Commercial Register or Trade Register with their actual operations, i.e. remove any redundant business activities.

We are here to help

We would be happy to assist you with assessing whether the registration requirement applies to your company, with registration in the goAML system itself, or with removing unnecessary business activities from the Commercial Register or Trade Register, depending on your needs.

The deadline is 30 November 2026, so please do not hesitate to contact us as soon as possible.