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: €2.8M+ a year · in the register since 2008
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 Insurance Association (GDV) · filed 17 Nov 2021 · source
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.
German Insurance Association (GDV) · filed 17 Nov 2021 · source
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.
German Insurance Association (GDV) · filed 17 Nov 2021 · source
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.
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.
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