You verified them at onboarding. The directors changed last month. You're still advancing funds.

Legal basis

CRD IV Annex I, Point 2 — factoring is explicitly named.

AMLR Regulation 2024/1624 applies from July 10, 2027. Factoring and invoice financing companies are financial institutions under AMLR Article 3 because CRD IV Annex I, Point 2 defines 'lending — including factoring, with or without recourse' as a financial institution activity. No size threshold. No exemption for dedicated businesses.

You must:

• Verify identity against reliable, independent sources — official government registries — not just customer-submitted documents (Article 22(6)(a))
• Maintain ongoing monitoring of customer records with documented refresh cycles (Article 26 — 12 months for high-risk, 5 years for standard)
• Identify natural persons for whose benefit transactions are conducted — directors, UBOs (Article 20(1)(h))

Fraud pattern

One fraudulent payout. Forty invoices of margin. Gone.

Invoice financing fraud follows a predictable pattern:

1. 1.

   A legitimate seller onboards. Everything checks out.

2. 2.

   Months later, the seller's vendor details change. New IBAN. New director. Sometimes a different entity with a similar name.

3. 3.

   You advance funds. To the wrong account.

4. 4.

   Recovery is expensive, slow, and often incomplete.

And from July 2027: if you did not verify against official registries with documented ongoing monitoring, you are also non-compliant. AMLA penalties: up to 10% of annual turnover or €10M, whichever is higher.

What we provide

AMLR-ready from day one.

• Registry-verified vendor identity before every payout — RCS (France) · Registro delle Imprese (Italy) · KvK (NL) · Handelsregister (DE) · Bolagsverket (SE) · and more
• Article 22(6)(a) — verified against reliable, independent sources. Direct government registry integrations. No aggregators. Meets the forthcoming AMLA CDD RTS standard at source.
• Article 26 — ongoing monitoring with documented refresh cycles. 12-month / 5-year cycle records generated automatically. Event-triggered alerts when circumstances change.
• Director and UBO identification — Article 20(1)(h). Natural persons behind each entity pulled from official registry at each verification.
• Full audit trail — exportable for regulator review. Every verdict timestamped, source-cited, uniquely identified.

Regulatory timeline

The deadline is July 2027. The preparation starts now.

Entities running registry-verified CDD workflows from 2026 are compliant from day one. Those building it in 2027 scramble.

AMLR-ready before the mandate arrives.

Currently onboarding design partners in France, Italy, Germany.