Prevention of the use of the financial system for the purposes of money laundering or terrorist financing

Input by Professional Committee of Art Galleries (CPGA-France) Regarding the Proposal for a Regulation of the prevention of the use of the financial system for the purpose of money laundering or terrorist financing (Brussels 20.7.2021 COM (2021) 420 final, 2021/0239 (COD)) WHAT REPRESENTS CPGA – Professional Committee of Art Galleries Since 1947, the Professional Committee of Art Galleries represents galleries in…

The Association Française des Sociétés Financières (ASF) represents in France the specialised credit, financial and investment services sectors. Its 270 members serve businesses and professionals (factoring, leasing of furniture and real estate, energy financing) and households (consumer credit and housing credit). They also offer a range of financial services (sureties) and investment services.

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The Electronic Money Association is the trade body for electronic money issuers and innovative payment service providers. Our members include leading payments and e-commerce businesses providing online/mobile payments, card-based products, electronic vouchers, crypto asset exchanges, electronic marketplaces, merchant acquiring services and a range of other innovative payment services.

The British Antique Dealers’ Association (BADA) is the trade body representing the leading fine art and antique dealers in in the United Kingdom. We are submitting our comments to the “Have your say” facility because our art dealer members conduct business with citizens of European Union (EU) countries, as well as with businesses located in the EU, notably with European art dealers and auction houses.

Adan's recommendations on the proposed Regulation establishing an Anti-Money Laundering Authority are contained in Part III "Comments on the introduction of an AML/CFT regulation " of the transmitted document. In summary : Firstly, about the harmonisation of the rules applicable to CASPs at the European level: Article 15 of the AMLR requires a CASP that initiates or executes an occasional transaction that…

The European Banking Federation (EBF) is fully supportive of the Commission’s overarching objective to address the ineffectiveness of the current EU AML framework. Bearing in mind the necessary lead-time and efforts to get the AML Package adopted and implemented, this momentum is a unique opportunity to improve the framework and cannot be missed. The EBF believes that there is a crucial need for a paradigm shift.

ÖRAK continues to fully support the EU’s anti-money laundering and counter-terrorism policy. The Bar has made considerable efforts in recent years to make the fight against money laundering and terrorist financing even more effective. All mechanisms are continuously reviewed and adapted for their effectiveness.

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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 welcomes the objective of harmonization pursued by the EC, however, it is important to ensure that the shift toward a more integrated EU AML/CFT framework should consider that in France, the insurance sector is already subject to an extensive AML/CFT framework which already reaches purposes of the new proposals. Please find attached the full FFA Position Paper for detailed comments on the AML Package.

Please find attached Insurance Europe's position paper on the Commission's AML legislative package. Thomas Gelin Senior policy advisor Insurance Europe is the European insurance and reinsurance federation. Through its 37 member bodies — the national insurance associations — it represents all types and sizes of insurance and reinsurance undertakings.

RELX is a global provider of information and analytics employing over 33.000 staff worldwide and serving customers in over 180 countries. Through our LexisNexis Legal & Professional and LexisNexis Risk Solutions businesses we support obliged entities (OEs) and other organisations with a range of financial crime prevention and compliance data services and software.

Finance Denmark thanks the Commission on the opportunity to provide feedback on the Commission's proposal for a regulation on preventing money laundering and terrorist financing. Finance Denmark supports the Commission’s Anti-money laundering and coun-tering the financing of terrorism legislative package and a new and revised reg-ulatory framework and supervision in the EU, and we strongly agree that in-creased…

EGBA is the Brussels-based industry body representing the leading online gaming and betting operators established, licensed and regulated within the EU. AML is of one the key compliance priorities for gambling operators coming from the licensing obligations and the very nature of our industry.

Association française des marchés financiers (AMAFI) is the trade organisation working at national, European and international levels to represent financial market participants in France. AMAFI mainly acts on behalf of investment firms and credit institutions (French, European and global firms), operating in and/or from France (corporate and investment banks – CIBs, brokers-dealers, exchanges, and private banks).

The Association of Foreign Banks in Germany (VAB) represses the interests of current more than 200 foreign banks and other financial services institutions which operate in Germany via subsidiary or branch. All member institutions are therefore part of a cross-border banking of financial group.

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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:

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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.

The Association of Charity Lotteries in Europe (ACLEU) represents a group of national charity lotteries that together raise well over 800 million EUR annually for civil society in Europe. This structural and unrestricted source of income is essential for 12,000 projects and civil society organisations across Europe to continue their important work in areas like nature preservation, health & wellbeing, human rights…

Allegro wants to thank the Commission for its work on the AML package and supports the goal to improve the AML framework as well as the objective to harmonise and streamline the AML regulation across Member States. Allegro is a European tech leader and the most popular e-commerce platform in Poland.

1. Parts of the previous directive are supposed to be adopted by the regulation, while other aspects of the regulation go beyond the previous directive. However, the regulation often contains referrals to either AMLA or the EU Commission to issue numerous regulatory technical standards (RTS).

EOS Group wishes to thank the European Commission for the opportunity to comment on its 2021 AML/CFT leg-islative package as we already did on the 2020 Action Plan. We hope that the new legislative initiatives and the future EU AML/CFT Authority will become a strong source of guidance and a true partner for businesses in their fight against money laundering and the financing of terrorism in the EU and beyond EU…

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.

While a more detailed anti-money laundering regulation is ineluctable for a single AML/CFT rulebook, it is essential that it does not undermine the fundamental principle of risk-based compliance with anti-money laundering requirements. The risk exposure of obliged insurance undertakings is deemed to be moderately significant.

The European Federation of Jewellery (EFJ) thanks the European Commission for the opportunity to provide inputs on the proposal for a regulation on “The prevention of the use of the financial system for the purposes of money laundering or terrorist financing.” The EFJ supports the introduction of a Union-wide limit for large cash payments of 10.000€ and welcomes the possibility left to Member States to adopt lower…

Dansk Erhverv supports the AML Regulation to help ensure a more uniform legal position across Member States, in line with developments in money laundering and terrorist financing. Dansk Erhverv hopes that the Regulation will contribute to the increased protection of EU citizens, and in particular the EU’s financial system, by setting higher standards reflecting the best practices used by EU financial institutions.

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ABI welcomes the EU Commission Proposals. The need to avoid regulatory fragmentation and consequently competitive disparities is of paramount importance. ABI highlights the following comments.The delegation to secondary regulation is understandable but may prevent from having clear the impact of the new regulation, since now.

We welcome the initiative launched by the European Commission to revise this framework in order to create a more coherent framework to facilitate compliance by operators subject to AML/CFT rules. The differences in application are causing considerable difficulties for operators, especially in cross-border relations and the introduction of common provisions valid for all Member States — and, hopefully, also in…

Filed in Italian · English published by the European Commission

ETPPA believes that additional amendments and clarifications are necessary in order to ensure that third party payment service providers (“TPPs”) are afforded a fair environment for competing with other payment options and payment service providers, in particular card-based payments.

EPIF very much welcomes the Commission’s proposals as part of the AML package. We have been strong supporters of moving to greater harmonization in the EU Anti-Money Laundering (AML) framework and we very much welcome the fact that parts of the Directives have been turned into a maximum harmonization Regulation.

In our view, Article 20 of the AMLR is ambiguous and should be made clear: To give you some background information, The AMLR contains, in Article 15 et seq., a potentially ambiguous systematic structure which suggests that the obligation laid down in Article 20 to identify the purpose of a transaction and the source of funds and destination of funds could always apply, that is to say, even in the case of occasional…

Filed in German · English published by the European Commission

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.

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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 20th of July to strengthen and uniformize the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules.

Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (Text with EEA…

BIPAR endorses the EU’s aim to improve the detection of suspicious transactions and activities, and to close any loopholes used to launder illicit proceeds or finance terrorist activities through the financial system.

ACCIE is delighted to submit feedback on the Commission's proposal for a Regulation on Anti-Money Laundering and Countering Terrorist Financing (AML/CTF). ACCIE welcomes the Commission’s aim to increase the protection of the EU financial system and citizens by setting stricter rules on transfers which are more prone to fraud, as well as by setting higher fraud prevention standards, reflecting the best practices…

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