Prevention of the use of the financial system for the purposes of money laundering or terrorist financing: mechanisms to be put in place by the Member States

Introduction The European Art Market Coalition (EAMC) represents auction houses and art and antique dealers’ organizations in Member States throughout the European Union. It is the leading pan-European art market group specifically representing this sector. Since 2010, it has worked with EC officials on a number of issues relating to cultural goods.

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 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.

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.

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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FFA welcomes the objective of strengthening the fight against money laundering within the EU, but it is important to ensure a level playing field for undertaking within the EU AML/CFT framework and to minimise costs related to central registers data.

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…

Finance Denmark thanks the Commission for the opportunity to provide feedback on the proposal. Finance Denmark supports the EU Commission’s Anti-money laundering and countering the financing of terrorism legislative package.

The Danish Chamber of Commerce supports the objective of the directive: strengthening the coordination between national financial intelligence units. The Danish Chamber of Commerce supports a deeper harmonization of anti-money laundering standards across the Union as well as greater coherence of the supervision undertaken by the national financial intelligence units.

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) represents the interests of currently more than 200 foreign banks and other financial services institutions which operate in Germany via subsidiary or branch. Almost all member institutions are therefore part of a cross-border banking of financial group.

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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Art. 21 still contains no obligation for FIUs to provide specific feedback. However, such feedback is necessary so that obliged entities can improve their suspicious activity reporting practices and thus optimise the prevention of money laundering as a whole. Additional note: The directive – as well as the regulation – does not contain a legal basis for the information exchange and information sharing between banks.

2021-0239 (COD) PROPOSAL FOR A REGULATION - COM(2021)420 - Article 58 Our principal business line in Ireland is physical and digital gift cards (both regulated electronic money (“Card”)) which, while restricted to our participating retailers, can be spent in over 11,000 stores nationwide and online. The Card is not eligible to rely on the limited network exemption set out in the PSD2.

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 welcomes the focus of the Draft Directive on the organizational aspects of the institutional AML/CFT system while keeping the requirements of obliged entities separate in the AML/CFT regulation. This concept grants Member States the necessary flexibility. Please find attached the full GDV Position Paper for detailed comments on the AML Package.

The Italian Banking Association appreciates the opportunity to provide its feedback. We support the objectives of Anti-Money Laundering and Countering the Financing of Terrorism Package. We recognise the importance of establishing an effective and cooperative AML/CFT environment which requires the combined efforts of obliged entities, competent authorities, FIUs, law enforcement and AMLA.

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 14th of July to strengthen and uniformize the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules.

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.

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