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EU consultation

Action Plan on anti-money laundering

27 submissions from 27 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission lists 247 submissions on this file. Shown here: the 27 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.

Who showed up

19 submissions from industry — companies and their trade associations — against 6 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 3.2 industry submissions for every one from civil society.

Industry 19Civil society 6Public authorities, academia, other 2

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.

What the room declares

13 of 27
in the EU Register
86
full-time lobbying staff
€19.4M+
declared costs a year
64
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 26 Aug 2020 — it ran from 7 May 2020.

Policy area
Financial services (DG FISMA)
Where it stands
Awaiting adoption

How it got here

  1. Roadmap11 Mar 2020
  2. Public consultation26 Aug 2020

Also on the Commission’s pipeline for this file, with no date recorded: Communication.

Showing 25 of 27 submissions.

R

RELX

· · filed 11 Mar 2020 · source

PDF

RELX is a global provider of information-based analytics and decision tools for professional and business customers. We welcome the opportunity to provide feedback to the Commission's Roadmap on anti-money laundering (AML) ahead of the presentation of the Commission's AML Action Plan. Please find attached our submission of feedback.

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HSBC

· · filed 11 Mar 2020 · source

PDF

HSBC Response to Commission 2020 AML Roadmap 11 March 2020 HSBC welcomes the opportunity to provide feedback on the European Commission’s 2020 AML Roadmap. As acknowledged in the Roadmap, recent money-laundering scandals have highlighted weaknesses in the current EU AML framework.

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EE

EY Europe SCRL

· · filed 11 Mar 2020 · source

PDF

Dear Sir/Madam EY Europe SCRL (“EY”) wishes to thank the European Commission (the Commission) for the opportunity to comment on its roadmap for a new comprehensive approach to preventing and combating money laundering and terrorism financing.

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EB

European Banking Federation

· · filed 11 Mar 2020 · source

PDF

Dear Sir/Madam, Please find enclosed a word (light) version of "LIFTING THE SPELL OF DIRTY MONEY", EBF BLUEPRINT FOR AN EFFECTIVE EU FRAMEWORK TO FIGHT MONEY LAUNDERING A full pdf version is available at: https://www.ebf.eu/wp-content/uploads/2020/03/EBF-Blueprint-for-an-effective-EU-framework-to-fight-money-laundering-Lifting-the-Spell-of-Dirty-Money-.pdf Best regards, [name removed]

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O

Onfido

· · filed 11 Mar 2020 · source

PDF

Onfido is pleased to feed into the Commission's roadmap for an Action Plan on anti-money laundering. Onfido is the global remote identity verification provider that works with 1,600 organisations worldwide, including many of the EU’s FinTech’s such as Adyen, Bunq, Getaround, Nickel, Revolut, Transferwise and Monese.

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AA

AFME - Association for Financial Markets in Europe

· · filed 11 Mar 2020 · source

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The Association for Financial Markets in Europe (AFME) is pleased to provide feedback on the European Commission’s roadmap on the upcoming initiative fora new comprehensive approach to preventing and combating money laundering and terrorism financing .

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FD

Finance Denmark

· · filed 11 Mar 2020 · source

Finance Denmark supports the European Commission's communication towards a new comprehensive approach to preventing and combatting money laundering and terrorism financing and we appreciate the opportunity to provide our view and feedback.

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EF

European Foundation Centre

· · filed 11 Mar 2020 · source

PDF

We welcome the opportunity as a loose coalition of non-profit organisations to share some initial comments and reflections on the European Commission Roadmap towards a new European policy on preventing and combating money laundering and terrorism financing as follows, We take note that the 2020 European Commission´s Work Programme announced that in order "to ensure the integrity of the European financial system and…

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TD

THALES DIS

· · filed 11 Mar 2020 · source

PDF

Thales DIS welcomes the opportunity given by the European Commission to comment on the action plan for AML & CTF. These comments have been produced from the prospective of a provider of technical solutions for KYC operated by either public or private organizations.

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E

ESBG

· · filed 11 Mar 2020 · source

PDF

ESBG fully supports preventing money laundering and curbing terrorist financing. In ESBG’s view, an urgent and useful next step is an enhanced cooperation between supervisors and regulators as well as a strengthened dialogue between them and the banking industry. It is also key to monitor and assess the proper implementation of the last AML Directives and the ESAs review.

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A

AMAFI

· · filed 11 Mar 2020 · source

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AMAFI welcomes the opportunity to give feedback on the Commission’s Roadmap regarding its action plan on anti-money laundering and countering financing of terrorism (“AML/CFT”) and supports with the EU’s ambition on this topic. Nowadays, regarding the importance taken by AML/CFT issues, investment firms are legitimately subject to many requirements on this topic.

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CE

Counter Extremism Project (CEP)

· · filed 11 Mar 2020 · source

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“Counter Extremism Project (CEP) and Berlin Risk have co-authored the policy paper, "Further Development of European Union Regulatory Framework for Cryptocurrencies necessary to Mitigate Risks of Terrorism Financing”.

Filed in German · English published by the European Commission

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WF

Wirtschaftsprüferkammer

· · filed 11 Mar 2020 · source

Dear Sir/Madam, your consultation on money laundering and terrorist financing — an action plan — gives you the opportunity to comment. We would like to thank you for this possibility and would like to explain our view as follows: The need for a comprehensive and effective EU approach to preventing and combating money laundering and terrorist financing is justified, inter alia, by the fact that the provisions of the…

Filed in German · English published by the European Commission

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EC

European Confederation of Institutes of Internal Auditing -ECIIA-

· · filed 11 Mar 2020 · source

ECIIA Response to the Roadmap: Towards a new comprehensive approach to preventing and combating money laundering and terrorism financing Thank you for the opportunity to share our thoughts. Internal Audit plays a very important role in helping to improve tools, procedures and processes in the fight against money laundering, terrorist financing and any misuse of the financial system.

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FW

Finance Watch

· · filed 11 Mar 2020 · source

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Please refer to the attached submission document, which is based on evidence collected as part of the Finance Watch report on groups of citizens that are at particular risk of financial exclusion and discrimination - https://www.finance-watch.org/wp-content/uploads/2020/03/FW-Report_Vulnerable_Groups_March2020.pdf The submission raises the specific issue of overlaps in the requirements in the 5th EU anti-money…

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Leaseurope

· · filed 11 Mar 2020 · source

Leaseurope, the European federation representing the leasing and automotive rental industries, supports the Commission’s aim of tackling money laundering within the EU, and to improve the implementation of the EU anti-money laundering framework.

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CS

CRYPTOVALUES SCARL

· · filed 11 Mar 2020 · source

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Dear Sir/Madam, my name is Federica Rocco and I am the Chief Executive Officer at CryptoValues consortium (the “Consortium”). The Consortium, founded in 2018 on the initiative of The Rock Trading S.r.l., together with other companies of the crypto industry, is an association that brings together some of the most reputable players and professionals in the blockchain and crypto-currency (/crypto-assets) sector.

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AF

AMLC-FIOD

· · filed 11 Mar 2020 · source

Dear sir/madam, Great initiative to initiate a debate on how to enhance the effectiveness of a combined European approach to prevent and tackle the issues of money laundering and terrorism finance. The Dutch Anti Money Laundering Centre (AMLC) embraces the idea of creating a cross-border European public body tasked with streamlining the combat against Money Laundering on a European Level.

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C

CINOA

· · filed 11 Mar 2020 · source

CINOA is the principal international confederation of art & antique dealer associations (www.cinoa.org). Established in 1935, CINOA is the global leader in representing the international art and antiques trade, setting benchmark standards for the industry and promoting a responsible art trade.

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AE

AECM - European Association of Guarantee Institutions

· · filed 10 Mar 2020 · source

PDF

AECM and its members acknowledge the efforts of the European Commission to further strengthen EU rules on anti-money laundering and counter-terrorist financing. At the same time, AECM members would like to draw attention to a double documentation and double due-diligence barrier its members are facing regarding the monitoring responsibilities of obliged entities under the 5th Anti-Money Laundering Directive…

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E

EFAMA

· · filed 10 Mar 2020 · source

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The European Fund and Asset Management Association (EFAMA*) welcomes the European Commission’s efforts to work towards an adequate implementation of the EU Anti-money laundering (AML) framework and look forward to engaging on the next steps in the March AML Action Plan.

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GL

Global Legal Entity Identifier Foundation (GLEIF)

· · filed 10 Mar 2020 · source

PDF

The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission on its Roadmap titled Towards a New Comprehensive Approach to Preventing and Combating Money Laundering and Terrorism Financing. GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the Roadmap.

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SR

Österreichischer Rechtsanwaltskammertag

· · filed 10 Mar 2020 · source

The ÖRAK (Austrian Bar) thanks the European Commission for the opportunity to comment on the Roadmap “Towards a new comprehensive approach to preventing and combating money laundering and terrorism financing”. The ÖRAK (Austrian Bar) notices that “central EU mechanisms/bodies to strengthen the preventive framework” are deemed to be an option for future EU measures.

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AD

Asociacion de Victimas de corrupción judicial

· · filed 8 Mar 2020 · source

There are many different Regulations and Directives to regulate and control money laundering. There are also several different reports published, like the “Supranational Risk assessment report”, the “Assessment of recent high-profile money laundering cases in the financial sector”, the “Financial intelligence Units” and the “Interconnection of central bank account registries report”.

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AN

Asociación de Victimas de Corrupcion Judicial

· · filed 6 Mar 2020 · source

There are Regulations and Directives to regulate and control money. There is several reports, published, the ‘Assessment of recent money restitution money laundering fines in the financial sector’, the ‘Financial intelligence operations’ and the ‘interconnectedness of central bank account register report’.

Filed in Spanish · English published by the European Commission

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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.