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Annual AML questionnaire: getting the firm ready

The firm-wide obligations of the Law of 18 September 2017 and the bar rules, marked one by one, with a readiness report to keep in the firm's files.

What the rule says

Rules verified on 07/10/2026

From 2027, every Belgian lawyer answers a yearly online AML questionnaire set up by the bars. A voluntary phase is planned, probably from November 2026 to March 2027 (AVOCATS.BE, 10/09/2026). Its questions are not public yet.

This checklist follows the firm-wide obligations of the Law of 18 September 2017 and the bar rules (version 2026-10). Mark each line done, to do or not applicable: what is missing comes with its next step and its source.

Your bar
Your firm

The obligations

Mark each line. A line left unmarked counts as to do.

Scope

  1. The firm knows which of its practice areas involve the activities of art. 5 §1 28°

    Legal duty · art. 5 §1 28°; OVB Codex art. 67

  2. A scope check is recorded when every new file is opened

    Good practice · art. 5 §1 28°

Risk assessment

  1. A written overall risk assessment covers clients, services and transactions, countries and channels, with the factors of Annexes I to III

    Legal duty · art. 16; art. 17

  2. The overall assessment is kept up to date, with a next review date, and can be shown to the bâtonnier

    Legal duty · art. 17

  3. A documented method assesses the risk of each client and matter, linked to the overall assessment

    Legal duty · art. 19 §2

Policies and procedures

  1. Written policies, procedures and internal controls cover client acceptance, due diligence, reporting, record keeping and internal control

    Legal duty · art. 8 §1, §2 1°

  2. A senior-level member has signed off the policies, and their effectiveness is checked

    Legal duty · art. 8 §3, §4

Responsible persons and internal reporting

  1. A person responsible at the highest level is named for the firm

    Legal duty · art. 9 §1

  2. An AML compliance officer (AMLCO) is named, with the integrity, expertise, availability and powers the role needs

    Legal duty · art. 9 §2, §3

  3. Staff can report a breach through an internal channel, and know the bar's external channel

    Legal duty · art. 10; art. 90

Staff and training

  1. Staff whose role requires it are trained in the law, the internal procedures, red flags and how to report

    Legal duty · art. 8 §2 3°; art. 11

  2. Staff are screened for integrity at hiring and assignment, in proportion to the role

    Legal duty · art. 8 §2 2° b)

  3. Each lawyer has at least 1 AML point in the judicial year (1 September to 31 August)

    Bar rule · OVB Codex art. 53

  4. Each lawyer has at least 2 AML points in the 2026 to 2028 period, encoded in LGO

    Bar rule · AVOCATS.BE Code art. 3.27 §1

Customer due diligence

  1. A procedure sets how clients and agents are identified and verified, when, and the limited cases of deferred verification

    Legal duty · art. 21-27; art. 30; art. 31; art. 37 §1

  2. A procedure covers beneficial owners, access to the UBO register works, and discrepancies go to the bâtonnier

    Legal duty · art. 23; art. 29; art. 74/1

  3. Clients, agents and beneficial owners are screened for PEP status and financial sanctions, with a named source

    Legal duty · art. 8 §1 3°; art. 41

  4. A procedure sets the enhanced measures for high-risk third countries, low-tax states and PEPs

    Legal duty · art. 38; art. 39; art. 41

  5. Clients are told before the work starts about the AML framework, the data collected and how long it is kept

    Bar rule · OVB Codex art. 71

  6. Ongoing monitoring is organised: what triggers an update of a file and how often files are reviewed

    Legal duty · art. 35; AMLR art. 26(2)

  7. If the firm relies on third-party introducers, it receives their information immediately and keeps final responsibility

    Legal duty · art. 42-44

Atypical transactions and reporting

  1. A template exists for the written analysis of atypical transactions

    Legal duty · art. 45; art. 46

  2. Everyone knows the reporting route: a suspicion goes to the bâtonnier, the work stops, and the client is never told

    Legal duty · art. 52; art. 53; art. 55

Record keeping and cash

  1. Records are kept 10 years, then erased, and the firm can say within CTIF's deadline whether a relationship existed in the past 10 years

    Legal duty · art. 60-63

  2. No cash payment above €3,000 is accepted, and real-estate prices are paid only by transfer or cheque

    Legal duty · art. 66 §2; art. 67; OVB Codex art. 73

Bar controls

  1. Questionnaires sent by the stafhouder are answered within the time set

    Bar rule · OVB Codex art. 72

  2. The firm follows the bars' announcements on the online questionnaire: a voluntary phase, probably from November 2026 to March 2027, then a yearly questionnaire from 2027

    Good practice · AVOCATS.BE, Lexgo 10/09/2026 · To be confirmed

Your result appears here

Mark each line. A line left unmarked counts as to do.

A firm of five lawyers at a Flemish bar that has never written its AML procedures.

How it works

What is known about the questionnaire

In an editorial published on 10 September 2026, AVOCATS.BE says that both community Ordres and every bar decided to set up an online platform, modelled on Luxembourg's, to which every Belgian lawyer will be connected:

  • a voluntary and anonymous phase, probably from November 2026 to March 2027, that helps decide for each matter whether it is in scope and which risk points to watch;
  • a mandatory questionnaire, every year from 2027, answered by every Belgian lawyer, to check and evaluate how their practice applies the law.

The platform's name, its regulatory basis, the exact dates and the questions are not public on 7 October 2026. This tool therefore does not reproduce the questionnaire: it follows the legal obligations the questionnaire will check.

How the tool works

  1. You choose your bar (AVOCATS.BE or OVB) and the size of the firm: the rules of each Ordre, and the firm-level organisation above 25 persons at the OVB, depend on them.
  2. For each obligation, the tool shows its article and its nature: legal duty, bar rule or good practice. You mark it done, to do or not applicable.
  3. The result lists first what remains to do, with the next step and its source, then what is done and what does not apply. No score and no percentage: the list says what is missing, not whether the firm is in order.
  4. The readiness report exports as PDF or Word, in the language you choose, with the checklist version (2026-10).

The obligations covered

  • Scope: the inventory of the activities of art. 5 §1 28° and the scope check when each file is opened.
  • The overall risk assessment (arts. 16 and 17) and the method for the individual assessment (art. 19). For the first, use the firm-wide assessment tool; for the second, the client risk assessment.
  • Policies, procedures and internal controls, their sign-off and their review (art. 8).
  • The person responsible at the highest level, the AMLCO and the internal whistleblowing channel (arts. 9 and 10).
  • Staff training (arts. 8 and 11), integrity screening, and the lawyers' training points (AVOCATS.BE Code art. 3.27, OVB Codex art. 53).
  • Due diligence: identification and verification, beneficial owners and the UBO register, PEPs and sanctions, enhanced and ongoing due diligence (arts. 21 to 41).
  • Atypical transactions, reporting to the bâtonnier and the tipping-off ban (arts. 45 to 55).
  • Record keeping for 10 years (arts. 60 to 63) and the €3,000 cash limit (arts. 66 and 67).

Points to check

  • The list replaces neither the questionnaire nor a bar control. It will be compared with the questionnaire once published, and versioned.
  • For a report, the AMLCO is the lawyer in charge of the file (Constitutional Court 114/2020, B.21): a person named at firm level does not report in place of the lawyer handling the file.
  • Your answers stay in your browser; only anonymous counters, without content, are sent when the page closes.

Verification

The rules were verified on 7 October 2026 against the consolidated text of the law, the AVOCATS.BE Code, the OVB Codex and the AVOCATS.BE editorial. The tool assists the lawyer, who remains responsible for the organisation of the firm.

Updated on 7 October 2026

Frequently asked questions

Is the annual AML questionnaire mandatory?

According to AVOCATS.BE, it will be mandatory every year from 2027 for every Belgian lawyer, after a voluntary and anonymous phase planned probably from November 2026 to March 2027. The regulatory basis and the exact dates are not published yet. At the OVB, the stafhouder can already send questionnaires (Codex art. 72); the Antwerp bar, for example, questions about 90 to 100 lawyers each spring.

What will the questionnaire ask?

The questions are not public on 7 October 2026. They will check how the practice applies the Law of 18 September 2017: that is why the tool follows the obligations of the law and the bar rules. The list will be compared with the questionnaire once it is published.

Must the firm name an AML officer?

The law requires a legal person to name a person responsible at the highest level (art. 9 §1) and provides for an AMLCO (art. 9 §2). Among lawyers, each lawyer is an obliged entity personally; the AVOCATS.BE booklet still advises firms to name one. A sole practitioner holds these roles personally. At the OVB, above 25 lawyers, staff and trainees, the measures are organised at firm level.

How many AML training points are required?

At AVOCATS.BE, at least 2 points over the 2026 to 2028 period, encoded in LGO (Code art. 3.27). At the OVB, at least 1 point per judicial year, from 1 September to 31 August (Codex art. 53). Staff whose role requires it must also be trained (art. 11 of the law).

Can the readiness report be shown to the bâtonnier?

Yes, as a working document of the firm. It lists what is done, what remains to do and the source of each obligation. It is neither a certificate nor a guarantee: the bâtonnier may ask for the overall risk assessment and the procedures themselves (art. 17).

A drafting aid based on the sources cited. To be reviewed and adapted by the lawyer; it is neither advice nor a guarantee of compliance.