Anti-Money Laundering Authority (AMLA)

EUCI welcomes the harmonisation and strengthening of the European framework applicable to the crypto-asset industry. The current European AML/CFT legislation is characterised by a lack of harmonisation. The AML/CFT obligations of reporting entities, in particular with regard to crypto-asset service providers, may vary considerably between Member States' national laws and facilitate "law shopping" by some actors.

As representatives of the art and antiques trade, CINOA supports effective measures against money laundering and terrorist financing and would like to work with the EU institutions to help provide information and insight into the art market sector and the sector’s business practices.

CINOA understands that Member States are responsible for the establishment but remain free to introduce rules going beyond those laid out in the package of proposals of which this draft Directive is a part, but only if they are justified on a risk-based approach.

The European Banking Federation (EBF) supports the objectives of the European Commission’s Anti-Money Laundering and Countering the Financing of Terrorism Package which aims to strengthen the fight against financial crime in Europe. The set-up of a new EU AML Authority (AMLA) is a crucial component of this package.

EU AML rulebook - feedback collated during a roundtable discussion held with MLROs of main banks in Malta: Outsourcing: one of the prohibitions on outsourcing is in relation to the drawing up and approval of internal policies, controls and procedures which is being interpreted as a prohibition in the outsourcing of the development of AML controls to external third parties - Many firms rely on external third parties…

ALFI supports the European Commission’s efforts to fight money-laundering and financing of terrorism and is in favour of harmonising further certain professional obligations of European financial industry stakeholders. This is to the benefit of the Luxembourg fund industry, which is largely cross-border.

Dansk Erhverv was in favour of the establishment of a single EU supervisory authority to help ensure effective supervision and uniform processing across Member States. Dansk Erhverv hopes that this can help to strengthen the protection of the EU’s financial system and of EU citizens by setting higher standards reflecting the best practices used by EU financial institutions.

Filed in Danish · English published by the European Commission

Finance Denmark supports the Commission’s Anti-Money Laundering and Coun-tering the Financing of Terrorism Package which aims to strengthen the fight against financial crime in Europe and, as an important part of the new initiatives, the establishment of a new EU AML Authority (AMLA). We find harmonisation of the cross-border area crucial.

We thank you for the opportunity to comment on the draft AMLA regulation. The creation of an EU anti-money laundering authority (AMLA) is to be welcomed, but caution is urged against over-regulation of the financial sector and over-emphasis on formal anti-money laundering provisions.

ÖRAK continues to fully support the EU’s anti-money laundering and counter-terrorism policy. The Office has made considerable efforts in recent years to further improve the efficiency of the fight against money laundering and terrorist financing. All mechanisms are continuously reviewed and adapted for their effectiveness.

Filed in German · English published by the European Commission

The Deutsches Steuerberaterverband e.V. (DStV) represents around 36 000 people throughout Germany, i.e. more than 55 % of self-employed professionals working in their own offices. It represents their interests in the fields of law governing the professions, tax, accountancy and auditing.

Filed in German · English published by the European Commission

Assogestioni supports the European Commission's approach of ensuring harmonised rules throughout the internal market with the proposed Regulation (AML Regulation) and establishing a new Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA).

The Italian Banking Association appreciates the opportunity to provide its feedback. The set-up of a new EU AML Authority (AMLA) is a crucial component of this package. It is hence of great importance that it brings true value to the effective fight against financial crime and does not simply introduce another layer of ex-post reporting.

The European Tax Adviser Federation (ETAF) is a European umbrella organisation for 280,000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. The main role and mission of ETAF is to represent the regulated tax profession at European level in liaising closely with European policy makers in order to promote good legislation in tax and professional matters.

From a general standpoint, France Invest welcomes the package of legislative proposals published by the Commission to strengthen European AML-CFT rules. We support the aim of a more harmonised implementation of the rules and supervision throughout the EU in order to ensure a level playing field among Member States.

Adan's recommendations on the proposed Regulation establishing an Anti-Money Laundering Authority are contained in Part II "Comments on the establishment of an AML/CFT authority" of the transmitted document. In summary : Adan welcomes the creation of a European anti-money laundering authority.

We strongly believe in the important fight by the European Union and international and national policy makers against money laundering and terrorism financing. We have however observed that elements of policy developed with good intentions has had unintended consequences on the NPO sector including the philanthropic sector.

FFA is of the opinion that AMLA could promote better coordination of national authorities and guarantee a harmonized application of AML/CFT rules within the Union. Nevertheless, crucial issues are determined at Level 2 (e.g., entities subject to direct supervision). Regarding the direct supervisory powers given to the AMLA, FFA call for more details to be provided at Level 1.

RELX is a global provider of information and analytics employing over 33.000 staff worldwide and serving customers in over 180 countries. Although RELX is not itself a financial institution or obliged entity, through our LexisNexis Legal & Professional and LexisNexis Risk Solutions businesses we support obliged entities and other organisations globally with a range of financial crime prevention and compliance data…

The German Notaries Association is the Federal Association of Chief Notaries in Germany. As part of the consultation, we comment on the above-mentioned legislative proposals of the European Commission on anti-money laundering and countering the financing of terrorism. We limit ourselves to key elements of the AML package related to notarial activity:

Filed in German · English published by the European Commission

Accountancy Europe welcomes the European Commission’s package of legislative proposals to strengthen the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules. Harmonization of Anti-Money Laundering (AML) rules and supervision will facilitate a more effective response to the challenges in the fight against money laundering.

The GDV supports the designation of a European Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) with direct supervisory responsibility for selected obliged entities with significant cross-border activities and a high inherent risk profile.

The CCBE represents the bars and law societies of 45 countries, and through them more than 1 million European lawyers. The organisation supports the fight against money laundering and has been actively engaged in countering existing and potential risks. Following the publication of the AML package, the CCBE elaborated preliminary comments on the package (attached).

Pepdata strongly welcomes the ambitious package of legislative proposals presented by the European Commission on the 14th of July to strengthen and uniformize the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules.

ACCIE is delighted to submit feedback on the Commission's proposal to eshtablish an European Anti-Money Laundering Authority (AMLA), and would like to highlight that AML supervision must be clearly divided across the different supervisory levels. This is necessary to prevent burdening market operators and avoid complicated reporting processes and unclarity amongst the market players.

Note of the French- and German-speaking bar association and Flemish bar association of Belgium (umbrella organisations of the Belgian bars) on the Commission's package of legislative proposals to strengthen the EU's rules on anti-money laundering and countering the financing of terrorism.

The Chamber of Tax Advisers and Accountants (KSW) is the legal representative of tax advisors and accountants in Austria. Its members are tax consultancy, auditing and auditing and accounting specialists. They care for more than 95 % of Austrian businesses. The Chamber represents more than 11.000 members.

Filed in German · English published by the European Commission