2022/0167(COD) · In Force
4 submissions from 4 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 72 submissions on this file. Shown here: the 4 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
0 submissions from industry — companies and their trade associations — against 1 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 27 Sept 2021 — it ran from 21 Jun 2021.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 4 of 4 submissions.
· · filed 6 Apr 2021 · source
Transparency International EU (TI-EU) welcomes the incept impact assessment and the issues identified with regards to Directive 2014/42/EU (Directive) and supports policy option 3. In particular, TI EU recommends the following reforms: Problem 1: The criminal offences included under the Directive should be aligned with that of Directive on Combating Money Laundering by Criminal Law 2018.
· · filed 6 Apr 2021 · source
With regards to the initiative to modernize the legal framework on freezing and confiscation of the proceeds and instrumentalities of crime and on ARO's we would support policy option no 4, a combination of legislative and non-legislative intervention.
Since the 2014/42/EU Directive the development in the area of the assets movement especially the facilitation of the money flow using services of the electronic money institutions (fintech) is immense and continues.
Entering into force of EU Regulation 2018/1805 sinc 19th December 2020 seems to have solved some of the problems stressed in the afore mentioned assessment document. Nevertheless, option 3 - even if it is for sure the most challenging between the four option shown in the assessment document - appears to be the best one.
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.