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04/06/2021


Adequate and proportionate AML/CFT regulation is also in the interest of the financial sector to further protect the integrity of the financial system. In its Paper, the EFR gives it views on some key aspects of the (upcoming) proposals of the European Commission on AML/CFT.

  • The EU rule book should be harmonised and significant parts of the Directive should preferably be transferred to a maximum harmonisation Regulation.
  • The EFR supports the proposal to set up a single EU AML authority under certain conditions, such as a clear mandate with sole responsibility for the entities that will fall under direct supervision, separating its tasks from other (existing) authorities, a risk based selection of directly supervised entities, avoiding duplication of (reporting) requirements and supervision, and cost efficiency and a governance open to other stakeholders having a concrete experience of the markets.
  • Direct EU AML oversight should not be limited to banks but should be broadened to encompass other actors which may present an AML risk.
  • Consistent and pervasive supervision of a harmonized and streamlined rulebook focused on effectiveness is essential to prevent criminals entering the financial system at the lowest entry point.
  • Information sharing in all its dimensions (between financial institutions and public-private) is a key enabler for making the system more effective.
  • A solid legal framework should be put in place authorising under specific conditions data sharing between public and private sectors while respecting requirements related to personal data protection principles such as data minimisation, proportionality and transparency.

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