Belgium's anti-money laundering regime has undergone significant revision. Companies operating in the country – particularly those with cross-border structures or international ownership chains – now face stricter obligations than at any point in the previous decade. Missing the compliance deadlines carries direct legal consequences, including administrative sanctions and potential suspension of banking relationships.
Belgium's updated AML legislation, aligned with the EU's successive anti-money laundering directives and transposed into Belgian law through amendments to the country's anti-money laundering and counter-terrorist financing legislation. Imposes enhanced know your customer (KYC) duties, reinforced beneficial owner disclosure requirements. Additionally, tightened rules on bank account opening and correspondent banking relationships. Obliged entities must complete internal compliance reviews and update their customer due diligence files within the timelines set by the Autorité des services et marchés financiers (FSMA) and the National Bank of Belgium. Companies that have not yet audited their compliance position are at immediate risk of regulatory exposure.
This alert outlines what has changed, which business categories are affected, and the specific actions international companies must take now.
What changed and when it takes effect
Belgium's AML legislative regime was substantially updated through amendments that entered into force in the course of 2024 and early 2025. The changes reflect the requirements of the EU's sixth anti-money laundering directive and the broader package of EU AML reforms. Belgian financial regulation now incorporates these requirements directly into domestic banking and finance legislation.
The principal changes affect four areas. First, the threshold for identifying a beneficial owner has been tightened. Direct and indirect ownership chains must now be traced with greater precision. Where no natural person can be identified above the ownership threshold through the chain, senior managing officials must be registered as the beneficial owner of record – with supporting documentation on file.
Second, KYC refresh obligations have been accelerated. Obliged entities are no longer permitted to rely on customer due diligence files that were compiled under earlier standards. Files must be updated to meet the current evidentiary standard, and gaps in documentation must be remedied proactively – not only when a transaction is triggered.
Third, rules governing bank account opening and the maintenance of existing accounts have been reinforced. Financial institutions in Belgium are required to apply enhanced scrutiny to accounts held by entities with complex ownership structures or accounts that involve correspondent banking relationships. Non-financial companies seeking to open accounts or maintain credit facilities with Belgian banks will encounter more detailed onboarding requests as a direct result.
Fourth, the obligations for non-financial obliged entities – including real estate intermediaries, accountants, notaries, lawyers, and company service providers – have been expanded. These sectors now face closer supervisory scrutiny and must demonstrate that their internal AML policies meet the updated standard.
The Cellule de traitement des informations financières (CTIF-CFI – the Belgian financial intelligence unit) has signalled that supervisory reviews will be intensified during 2025 and 2026. Belgian supervisors have authority to impose administrative fines, issue public warnings, and – in serious cases – refer matters for criminal prosecution.
Which companies are affected and the compliance deadline
The updated obligations apply broadly. The following categories of entity face the most immediate exposure.
- Financial institutions and payment service providers licensed in Belgium or passporting into Belgium from another EU member state.
- Non-financial businesses classified as obliged entities under Belgian AML legislation – including real estate agents, auditors, tax advisers, legal professionals, and trust and company service providers.
- Foreign companies with Belgian subsidiaries, branches, or permanent establishments that maintain accounts or credit facilities with Belgian financial institutions.
- International holding structures with Belgian entities in the ownership chain, particularly where the beneficial owner register entry has not been reviewed since 2022.
- Companies engaged in correspondent banking arrangements with Belgian counterparties.
The compliance deadline for updating KYC files and beneficial owner documentation is not a single fixed date. Belgian law operates on a risk-based timeline. High-risk customers and high-risk sectors face the shortest refresh cycles – in many cases, remediation should already be underway. Medium-risk relationships must be reviewed within rolling 12-month periods. All obliged entities were expected to have completed a full internal gap analysis by the end of the first quarter of 2025. Companies that have not done so are already outside the expected supervisory timeline.
For international companies, the risk is compounded. A foreign parent company that cannot produce a clear beneficial owner chain to the satisfaction of Belgian supervisors may find that its Belgian subsidiary faces account restrictions or loses access to credit facilities. Belgian banks are acting on supervisory guidance and are declining or suspending account relationships where documentation is inadequate – regardless of the length of the existing banking relationship.
To discuss how these obligations apply to your Belgian operations, contact us at info@ferrazwhitmore.com for a preliminary review.
Immediate actions for international companies
Companies with Belgian operations or banking relationships should take the following steps without delay.
Review beneficial owner registrations. Confirm that the entry in the Registre UBO (UBO Register – Belgium's central beneficial ownership register) accurately reflects the current ownership and control structure. Any change in the ownership chain since the last filing must be updated. Errors or omissions in the UBO Register are independently sanctionable.
Audit existing KYC files. Internal compliance teams – or external counsel – should assess whether customer due diligence files held by Belgian obliged entities meet the current evidentiary standard. Files compiled before the 2024 legislative changes are likely to require supplementation.
Prepare documentation for bank account opening or renewal. If your company is in the process of opening a new account with a Belgian bank. Alternatively. If an existing account is subject to a periodic review, assemble the complete ownership chain documentation in advance. Belgian financial institutions are requesting notarised or apostilled corporate documents, translated into French, Dutch, or German as applicable.
Review correspondent banking arrangements. Where your business relies on correspondent banking with Belgian institutions, confirm that the due diligence exchange between your institution and the Belgian correspondent meets the updated standard on both sides.
Train relevant staff and update internal policies. Belgian AML legislation requires that obliged entities maintain documented internal policies and provide AML training to relevant personnel. Policies drafted before 2024 should be reviewed against current requirements. A gap in documented staff training is a frequently cited finding in supervisory reviews.
For companies seeking advice from a lawyer in Belgium with cross-border AML experience, or those looking for a law firm in Belgium to support their compliance review, our team is available to provide structured guidance. For related developments in the Portuguese AML space, see our alert on AML compliance updates in Portugal. Companies with capital markets exposure in Belgium should also review the intersection of AML obligations and securities regulation, covered in our analysis of capital markets in Belgium.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our banking and finance practice covers AML compliance, KYC frameworks, beneficial owner disclosure, and regulatory engagement with Belgian and EU financial supervisors. The firm's team combines Portuguese civil law expertise with English common law tradition – a combination that is particularly relevant for cross-border structures subject to multiple AML regimes simultaneously. Our attorneys have advised international companies on AML compliance reviews, UBO Register filings, and bank account opening procedures across both civil law and common law systems. Ferraz & Whitmore participates in cross-border practice groups focused on financial regulation and is a member of leading international legal associations. To discuss your compliance position in Belgium, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.