Customer data fields for AMLR due diligence

legal_name

Free text, UTF-8, max 300 chars

The full registered name of the entity exactly as recorded in the official company register of the country of incorporation, including the legal-form suffix.

AMLR Art. 22(1)(b) — "the name"

Store verbatim from the register, never a normalised or truncated version.

legal_form

Coded value (ISO 20275 ELF code) + free text

The legal form of the entity (e.g. AB, GmbH, S.A., Ltd), captured as a separate attribute even when it is part of the legal name.

AMLR Art. 22(1)(b) — "legal form"

legal_name_latin

Free text, Latin script

Transliteration of the legal name into Latin script when the register entry uses a non-Latin script (Cyrillic, Greek, Arabic, Chinese, etc.).

Required for sanctions and PEP screening; both versions must be screened.

trading_names

Array of free text

Business, trading or brand names the entity uses commercially and that differ from the legal name (doing-business-as).

Needed for transaction-monitoring alerts and adverse-media matching.

previous_names

Array of {name, valid_from, valid_to}

Former legal names with the date range each was in force, including names carried over through mergers.

Frequent renaming is a risk indicator and old names may still appear on sanctions lists.

registration_number

Free text as printed by the register

The identifier assigned to the entity in the official register, which binds the name to a unique entity.

AMLR Art. 22(1)(b) — "registration number"

register_name_and_country

Free text + ISO 3166-1 alpha-2

Which register the name was taken from and the country/jurisdiction of incorporation.

Two entities can share a name across jurisdictions; the register plus country disambiguates them.

lei

ISO 17442, 20 alphanumeric characters

Legal Entity Identifier, where the entity has one.

Strongest key for reconciling names across data sources.

euid

EUID string

European Unique Identifier from the Business Registers Interconnection System, for EU entities.

name_source

Coded value + document reference

The document or data source the name was verified against (register extract, certificate of incorporation, register API).

AMLR Art. 24 — verification against independent and reliable sources

name_verified_on

ISO 8601 date

Date the name was verified, and the date it was last refreshed.

Drives the ongoing-due-diligence refresh cycle.

name_screening_result

Coded result + list version + ISO 8601 timestamp

Outcome of sanctions, PEP and adverse-media screening performed on each stored name variant, with list version and timestamp.

Screen legal name, Latin transliteration, trading names and previous names — not just the legal name.

entity_status

Coded value

Register status of the entity (active, dissolved, in liquidation, struck off) as at the verification date.

A name that resolves to a dissolved entity is a red flag for onboarding.

country_of_incorporation

ISO 3166-1 alpha-2

Jurisdiction where the entity is legally registered.

AMLR Art. 22(1)(b)

Drives geographic risk scoring and the high-risk third-country checks under Art. 29.

date_of_incorporation

ISO 8601 date

Date the entity was entered in the register.

Newly formed entities used for high-value activity are a risk indicator.

tax_identification_number

Free text + ISO 3166-1 alpha-2

National tax number(s) of the entity, with issuing country.

vat_number

VIES format

EU VAT identification number where the entity is VAT registered.

nace_code

NACE Rev. 2 code + description

Principal economic activity of the entity.

AMLR Art. 20(1)(c) — understanding the nature of the business

Used for sector risk scoring and to test whether transactions match the stated business.

listed_status

Boolean + market identifier (MIC)

Whether the entity is listed on a regulated market and where, including whether it is subject to disclosure requirements ensuring adequate transparency of ownership.

AMLR Art. 22(3)

Affects the extent of beneficial ownership identification required.

regulated_status

Coded value + licence reference

Whether the entity is itself a supervised obliged entity, with regulator and licence number.

Relevant to simplified due diligence eligibility under Art. 33.

group_affiliation

Entity references + LEI

Parent entity, ultimate parent and group identifier where the customer is part of a group.

registered_office_address

Structured address (street, number, postcode, city, region, ISO 3166-1 alpha-2)

The address recorded in the official register.

AMLR Art. 22(1)(b) — "address of the registered office"

head_office_address

Structured address

Address of the head office where this differs from the registered office.

AMLR Art. 22(1)(b) — "and head office, if different"

principal_place_of_business

Structured address

Where the entity actually carries out its main activity.

Flag when this sits in a different jurisdiction from incorporation.

correspondence_address

Structured address

Postal address used for communication where different from the above.

address_type_flags

Coded value

Whether the address is a serviced/virtual office, a registered-agent address, a c/o address or a PO box.

Mass-registration addresses shared by hundreds of entities are a shell-company indicator.

address_verification

Coded source + document reference + ISO 8601 date

Source and date of address verification (register extract, utility bill, government database).

AMLR Art. 24 — verification against reliable, independent sources

address_history

Array of {address, valid_from, valid_to}

Previous addresses with the period each was in force.

given_names

Free text, UTF-8

All first and middle names as printed on the identity document.

AMLR Art. 22(1)(a) — "the first name(s) and surname"

surname

Free text, UTF-8

Family name(s), including compound and maiden names.

AMLR Art. 22(1)(a)

name_latin_transliteration

Latin script

Machine-readable-zone transliteration of the name for non-Latin scripts.

Screen both the native and transliterated forms.

date_of_birth

ISO 8601 date

Full date of birth, not just the year.

AMLR Art. 22(1)(a) — "place and full date of birth"

place_of_birth

Free text + ISO 3166-1 alpha-2

City/town and country of birth.

AMLR Art. 22(1)(a)

nationalities

Array of ISO 3166-1 alpha-2

All nationalities held, or statelessness, including recently acquired citizenships.

AMLR Art. 22(1)(a) — "nationality or nationalities"

Citizenship-by-investment nationalities are an explicit risk factor.

residential_address

Structured address

Usual residential address; the country of residence at minimum where a full address is unavailable.

AMLR Art. 22(1)(a)

national_identification_number

Free text + ISO 3166-1 alpha-2

National identity number, personal number or equivalent, with issuing country.

AMLR Art. 22(1)(a)

Where no such number exists, record the identity document number instead.

gender

Coded value

Gender as stated on the identity document, where captured.

Only where needed for identity matching; minimise under data protection rules.

deceased_flag

Boolean + ISO 8601 date

Whether the person is recorded as deceased, with date and source.

document_type

Coded value

Type of document used to verify identity (passport, national ID, residence permit, driving licence).

AMLR Art. 24

document_number

Free text

Serial number of the document.

issuing_country_and_authority

ISO 3166-1 alpha-2 + free text

Country and authority that issued the document.

issue_and_expiry_date

ISO 8601 dates

Date of issue and date of expiry.

Expired documents must trigger re-verification during ongoing due diligence.

verification_method

Coded value

How identity was verified: physical presence, certified copy, remote video, eIDAS electronic identification, qualified trust service, or a supervised digital identity scheme.

AMLR Art. 22(6) and Art. 24

Remote/non-face-to-face onboarding is a risk factor in Annex III.

liveness_and_biometric_result

Coded result + score + vendor reference

Result of liveness detection and face match where remote identification was used, with vendor and score.

document_authenticity_check

Coded result

Outcome of chip/NFC read, MRZ checksum, hologram or database validation.

verification_performed_by

User/system identifier

Person or system that performed and approved the verification.

Needed for the audit trail and the record-keeping obligation.

document_image_reference

Document store reference + ISO 8601 date

Pointer to the stored copy of the document, with retention date.

AMLR Art. 77 — retention of CDD records for five years

representative_person

Reference to natural person record

Full identification data of the representative, using the natural-person field set.

AMLR Art. 25(1)

representative_role

Coded value

Capacity in which the person acts: director, authorised signatory, power of attorney, guardian, legal representative.

authorisation_evidence

Document reference

Document establishing the authorisation (board resolution, register extract of signatories, power of attorney).

AMLR Art. 25(1) — verification of authorisation

authorisation_scope_and_limits

Structured text + limits

What the person may do, including monetary or product limits and joint-signature requirements.

authorisation_validity

ISO 8601 dates

Start and end date of the mandate.

Expired mandates must block instruction acceptance.

revocation_record

Boolean + ISO 8601 date + user reference

Whether and when the mandate was revoked, and by whom.

ubo_person

Array of natural person references

Identification data for each beneficial owner, using the natural-person field set.

AMLR Art. 22(1) and Chapter IV

basis_of_beneficial_ownership

Coded value

Whether the person qualifies through ownership interest, through control via other means, or as a senior managing official where no owner is identified.

AMLR Art. 51, Art. 52, Art. 53 and Art. 54

Record explicitly when the senior-managing-official fallback is used, and why.

ownership_percentage

Decimal percentage, two decimals

Direct and indirect share of capital and of voting rights held, calculated through the chain.

AMLR Art. 51 — 25% threshold as an indication

Store direct and effective (multiplied through the chain) percentages separately.

direct_ownership_percentage

Decimal percentage, two decimals

Ownership interest held directly in the customer entity, before multiplying through intermediate layers.

AMLR Art. 52

indirect_effective_percentage

Decimal percentage, two decimals

Ownership interest calculated by multiplying each layer's stake along the chain and summing parallel chains.

AMLR Art. 52

Aggregation is required when several natural persons hold interests through the same intermediate entity.

voting_rights_percentage

Decimal percentage, two decimals

Percentage of voting rights held directly and indirectly, which may differ from capital ownership.

AMLR Art. 51 and Art. 52

Control can exist with low or no capital stake if voting rights are concentrated.

ownership_interest_type

Coded value + free text

The instrument through which ownership is held: shares, units, voting shares, non-voting shares, options, convertible instruments or other.

AMLR Art. 52

control_other_means

Structured text + coded categories

Control not based on shareholding: shareholder agreements, veto rights, right to appoint or remove management, dominant influence, control through debt or contracts.

AMLR Art. 51 and Art. 53

right_to_appoint_remove_body

Boolean + document references

Evidence that a natural person can appoint or remove a majority of the administrative, management or supervisory body, or senior management.

AMLR Art. 53 — control via other means

shareholders_agreement_veto

Document reference + summary of terms

Shareholders' agreements, veto rights or similar arrangements that confer decisive influence over strategic decisions.

AMLR Art. 53

significant_influence_indicators

Structured text

Other indicators of dominant or decisive influence, such as profit distribution rights, residual-asset claims or de facto decision-making.

AMLR Art. 53

senior_managing_official_fallback

Natural person reference + free-text justification

Where no beneficial owner is identified under Articles 52 and 53, the natural person(s) holding the position of senior managing official and the record of steps taken.

AMLR Art. 54

This is a last-resort fallback, not a default. Document why ownership and control tests yielded no result.

ownership_chain

Graph of {entity, jurisdiction, stake, layer}

Full chain of intermediate legal entities and arrangements between the customer and each beneficial owner.

Number of layers and offshore jurisdictions in the chain are strong risk indicators.

bearer_share_or_nominee_identification

Boolean + party references + evidence

Where shares are bearer shares or held by nominees, the natural person who ultimately owns, controls or benefits from them.

AMLR Chapter IV — transparency of ownership

Bearer shares and nominee arrangements are classic opacity techniques.

nominee_arrangements

Boolean + party references

Whether nominee shareholders or nominee directors appear in the chain, and who the nominator is.

trust_roles

Array of {role, person reference}

For trusts and similar arrangements: settlor, trustee, protector, beneficiaries or class of beneficiaries, and any other person exercising ultimate control.

AMLR Art. 58

Each role must be identified separately, not collapsed into one "owner" field.

register_cross_check

Coded result + ISO 8601 date + register reference

Result of consulting the central beneficial ownership register, including any discrepancy found.

Discrepancies between register data and your findings must be reported to the register.

ubo_verification_evidence

Array of document references

Documents or sources used to verify each beneficial owner and each link in the chain.

AMLR Art. 24

ubo_as_of_date

ISO 8601 dates

Date the ownership picture was established and the date it must next be refreshed.

source_of_funds_for_stake

Coded value + evidence references

How the beneficial owner acquired or funds the ownership stake, where enhanced due diligence or PEP considerations apply.

AMLR Art. 34 (EDD) and Art. 42 (PEPs)

ubo_pep_status

Boolean + coded PEP role + ISO 3166-1 alpha-2 + date range

Whether the beneficial owner is a PEP, family member or known close associate, including function, country and dates.

AMLR Art. 42

ownership_change_alerts

Array of {date, change, source, follow-up}

Record of any subsequent change in shareholding, control rights or senior management that triggers a refresh of the beneficial ownership picture.

AMLR Art. 26 — ongoing monitoring

relationship_purpose

Coded value + free text

Why the customer wants the relationship, in coded categories plus a narrative.

AMLR Art. 20(1)(c)

products_and_services

Array of product codes

The products and services the customer is expected to use.

expected_activity_volume

Numeric + currency + period

Expected number and value of transactions per period, by product.

Without this baseline, deviation-based monitoring cannot function.

expected_counterparty_countries

Array of ISO 3166-1 alpha-2

Countries the customer expects to send funds to or receive funds from.

Compare against the high-risk third-country list under Art. 29.

expected_transaction_types

Array of coded values

Payment types expected: cash, card, wire, crypto, cheque, correspondent flows.

cash_usage_expectation

Boolean + amount + currency

Whether and to what extent the customer expects to use cash.

AMLR Art. 80 — EUR 10 000 cash payment limit

employment_or_business_activity

Free text + NACE/ISCO code

Occupation for individuals, or the actual business activity for entities, in the customer's own words plus a code.

relationship_start_date

ISO 8601 date

Date the business relationship was established.

AMLR Art. 23 — timing of verification

source_of_funds_category

Coded value

Origin of the funds entering the relationship: salary, business income, sale of assets, inheritance, loan, investment returns, gift.

source_of_funds_evidence

Array of document references

Supporting documentation: payslips, audited accounts, sale contract, loan agreement, tax return.

AMLR Art. 34 — enhanced due diligence

Mandatory in high-risk situations and for PEPs.

source_of_wealth_narrative

Structured text + timeline entries

How the customer's overall wealth was accumulated, with periods and amounts.

AMLR Art. 42 — PEPs, family members and close associates

source_of_wealth_evidence

Array of document references

Independent evidence corroborating the wealth narrative.

plausibility_assessment

Coded conclusion + free text + user reference

The analyst's conclusion on whether funds and wealth are consistent with the customer profile, with reasoning.

Record the reasoning; an unexplained conclusion is not defensible to a supervisor.

funding_account_details

IBAN/account reference/wallet address + holder name

The account, wallet or instrument the funds arrive from, including holder name where available.

Third-party funding that does not match the customer name is a red flag.

sanctions_screening_result

Coded result + match score

Outcome of screening against UN, EU and applicable national sanctions lists, for every name variant held.

AMLR Art. 20(1)(d) — verification against targeted financial sanctions lists

list_version_and_timestamp

List identifier + version + ISO 8601 timestamp

Which list version was used and exactly when the screening ran.

Essential to prove what you could reasonably have known at a point in time.

pep_status

Boolean + coded function + ISO 3166-1 alpha-2 + date range

Whether the person holds or has held a prominent public function, with the function, country and dates.

AMLR Art. 2(1)(34) and Art. 42

pep_relationship_type

Coded value

Whether the person is a PEP themselves, a family member, or a known close associate.

AMLR Art. 2(1)(35)–(36)

pep_declassification_date

ISO 8601 dates

When a former PEP ceased to hold the function and the date risk was reassessed.

AMLR Art. 45 — measures applied for at least 12 months after ceasing the function

Risk-based; do not auto-clear at 12 months without an assessment.

senior_management_approval

Approver identity + ISO 8601 timestamp + decision

Record of senior management approval to establish or continue the relationship where required.

AMLR Art. 42(1)(a) — PEP relationships require senior management approval

adverse_media_findings

Array of {source, date, category, assessment}

Negative news hits with source, date, allegation category and materiality assessment.

match_disposition

Coded value + free text + user reference + timestamp

True match, false positive or discounted, with the reason and the analyst who decided.

Every discounted match needs a documented reason; this is a standard supervisory sampling point.

rescreening_frequency

Period + ISO 8601 timestamp

How often the record is rescreened and when it last ran.

AMLR Art. 26 — ongoing monitoring

risk_rating

Coded value (e.g. low / medium / high / unacceptable)

Overall customer risk classification.

AMLR Art. 20(2)

risk_factor_scores

Array of {factor, value, weight, score}

Individual factor scores for customer, product/service, delivery channel, geography and transaction risk.

AMLR Annexes II and III

risk_model_version

Version string

Version of the scoring methodology applied.

Needed to explain why the same customer scored differently at different times.

manual_override

Coded direction + free text + user reference + ISO 8601 date

Any manual change to the calculated rating, with justification, approver and date.

Downward overrides are a supervisory focus area.

edd_applied

Array of coded measures + trigger

Which enhanced due diligence measures were applied and why.

AMLR Arts. 34–36

sdd_applied

Array of coded measures + justification

Which simplified due diligence measures were applied and the lower-risk justification.

AMLR Art. 33

high_risk_third_country_exposure

Boolean + ISO 3166-1 alpha-2 array

Whether the customer, beneficial owner or counterparties are connected to a country identified as high-risk.

AMLR Art. 29 — enhanced measures for high-risk third countries

next_review_date

ISO 8601 date

When the profile must next be reviewed, derived from the risk rating.

AMLR Art. 26 — keeping documents and information up to date

transaction_identifier

String

Unique reference for each transaction.

AMLR Art. 77 — record keeping

amount_and_currency

Decimal + ISO 4217 + rate

Value and currency of the transaction, plus the base-currency equivalent and the rate used.

value_and_booking_date

ISO 8601 timestamps

Execution date/time and booking date.

counterparty_details

Free text + identifier + ISO 3166-1 alpha-2

Name, account/wallet identifier and country of the counterparty.

Regulation (EU) 2023/1113 (TFR) for transfers of funds and crypto-assets

payment_purpose_and_reference

Free text

Stated purpose and the free-text remittance reference.

Retain unaltered; truncated references break downstream monitoring.

channel_and_instrument

Coded value

How the transaction was initiated: branch, online, mobile, API, card, ATM, correspondent.

cash_indicator

Boolean + decimal + ISO 4217

Whether cash was involved and the amount.

AMLR Art. 80 — limit of EUR 10 000 on cash payments

profile_deviation_flag

Boolean + deviation metric

Whether the transaction deviates from the expected activity captured at onboarding, and by how much.

AMLR Art. 26(1)

alert_reference

Array of {alert id, scenario, score, status, closure reason}

Monitoring alerts raised, with scenario, score, assignee and outcome.

review_history

Array of {date, trigger, findings, user}

Record of each periodic or event-driven review of the relationship, with trigger, findings and reviewer.

AMLR Art. 26(2)

internal_escalation

{user, ISO 8601 timestamp, free text}

Internal report raised by staff, with who raised it, when, and the concern described.

suspicion_decision

Coded decision + free text + user reference + timestamp

Whether suspicion was confirmed or dismissed, by whom, with reasoning.

AMLR Art. 69(1)

Dismissed cases must be documented as thoroughly as reported ones.

str_reference

String + ISO 8601 timestamp

Reference number of the report submitted to the FIU and the submission timestamp.

AMLR Art. 69

predicate_offence_indication

Coded value

Suspected underlying offence category where identifiable.

fiu_feedback_and_instructions

Free text + document reference + timestamp

Any response, request for information or instruction to refrain from executing a transaction.

AMLR Art. 69(2) — abstaining from carrying out transactions

tipping_off_controls

Access control list + coded restriction

Access restrictions applied to the case record to prevent disclosure to the customer.

AMLR Art. 73 — prohibition of disclosure

relationship_exit_record

Coded reason + user reference + ISO 8601 date

Where the relationship was terminated or refused, the decision, the reason and the approver.

AMLR Art. 21 — inability to comply with due diligence requirements

record_created_and_modified

ISO 8601 timestamps + user references

Creation timestamp, last modification timestamp and the user or system responsible for each change.

field_level_change_log

Append-only array of {field, old value, new value, user, timestamp}

Immutable history of previous values for every due diligence field.

Overwriting a CDD value without history destroys the evidence you would need in an inspection.

retention_expiry_date

ISO 8601 date

Date each record becomes due for deletion, calculated from the end of the relationship.

AMLR Art. 77 — five-year retention period

legal_hold_flag

Boolean + reason + authority reference

Whether deletion is suspended because of an ongoing investigation or a national extension of the retention period.

data_source_lineage

Source identifier + ISO 8601 timestamp

For every stored value, which system or provider it came from and when it was last refreshed.

Needed to answer "where did this come from" during supervision.

third_party_reliance_record

Party reference + coded scope + agreement reference

Where due diligence was performed by a third party, who it was, what was relied on, and confirmation that the underlying data is available on request.

AMLR Arts. 48–50 — reliance on third parties

Ultimate responsibility stays with the obliged entity relying on the third party.

outsourcing_record

Party reference + coded functions + ISO 8601 date

Functions outsourced to a service provider, with the agreement, the controls and the date of the last assurance review.

AMLR Arts. 51–53 on outsourcing arrangements