Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Industry association · Italy
Industry association · Germany
Declared costs: under €10K a year · in the register since 2009
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 · Anti-Money Laundering Authority (AMLA)
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
Associazione Bancaria Italiana - ABI · filed 17 Nov 2021 · source
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.
Associazione Bancaria Italiana - ABI · filed 17 Nov 2021 · source
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.
German Banking Industry Committee · filed 17 Nov 2021 · source
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).
German Banking Industry Committee · filed 18 Nov 2021 · source
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.
Associazione Bancaria Italiana - ABI · filed 26 Nov 2021 · source
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.
German Banking Industry Committee · filed 29 Nov 2021 · source
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.
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