Occasional Transaction
An occasional transaction under MLR 2017 Regulation 27 is a single transaction (or a series of linked transactions that appear to be a single operation) carried out outside an established business relationship. CDD is triggered when an occasional transaction reaches €15,000 — or any lower threshold the firm sets in its own risk-based policies.
a one-off engagement for a non-recurring client should be assessed against the occasional-transaction threshold. Many firms apply full CDD regardless of value, on the basis that the marginal cost is low and the risk of inadvertently splitting linked transactions to stay below threshold is real.
How different roles use Occasional Transaction
A good definition should change the next action for the person reading it.
Partner or director
Check whether this term affects acceptance risk, fee scope, supervision exposure, or sign-off responsibility.
ContinueMLRO or compliance lead
Map the term to evidence, escalation, monitoring, training, and inspection readiness.
ContinueClient-facing team member
Use the plain-English explanation to ask better client questions and write clearer file notes.
ContinueOther terms that go with Occasional Transaction
A business relationship under MLR 2017 Regulation 4 is a relationship between a regulated firm and a client that has, or is expected to have, an element of duration. Acceptance of a client into a business relationship triggers the full set of CDD obligations under Regulation 28, including identity verification, beneficial-ownership identification, and ongoing monitoring throughout the life of the engagement.
Customer Due Diligence is the core legal obligation under MLR 2017 to identify clients, verify their identity using reliable independent sources, and understand the purpose and intended nature of the business relationship. Standard CDD applies to most clients. Where risk is elevated, Enhanced Due Diligence (EDD) is required instead.
Before you treat Occasional Transaction as handled
- Confirm which regulation, policy, or internal procedure the term maps to.
- Document the decision or evidence trail in the client file, not only in email or chat.
- Escalate where the term indicates higher risk, sanctions exposure, PEP status, suspicion, or missing evidence.
- Keep the wording consistent across onboarding, review notes, training material, and inspection packs.
Put Occasional Transaction into practice with Certivus
Knowing the term is the first step. Certivus gives you the workflows — client intake, CDD, EDD, PEP and sanctions screening, audit-ready records — to apply it across every client.
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