KYC/AML for smaller institutional clients in Europe post-MiFID II

Hey everyone,

Been thinking a bit lately about the ongoing evolution of KYC/AML requirements, especially for smaller institutional clients within the EU. Post-MiFID II, it feels like the goalposts are constantly shifting, and what was sufficient even a year or two ago might be seen as lacking now. It's not just about ticking boxes anymore; regulators are clearly looking for a deeper understanding of beneficial ownership and the source of funds.

My question is, for those of you dealing with a diverse client base across different European jurisdictions – particularly smaller funds or corporate treasuries that don't have the same extensive infrastructure as a large investment bank – what are the biggest practical challenges you're facing in keeping compliant? Are certain countries particularly difficult, or are there common red flags that are becoming more prevalent? I'm trying to gauge if our internal processes are aligned with what others are seeing as best practices, or if we need to lean harder into new tech solutions for ongoing monitoring. It feels like a constant balancing act between operational efficiency and the ever-increasing scrutiny.