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 · Belgium
Declared costs: €10K+ a year · in the register since 2017
Trade union · Belgium
Declared costs: €4M+ a year · in the register since 2008
Prevention of the use of the financial system for the purposes of money laundering or terrorist financing · Anti-Money Laundering Authority (AMLA) · Action Plan on anti-money laundering
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.
CINOA · filed 18 Nov 2021 · source
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.
European Banking Federation · filed 18 Nov 2021 · source
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.
European Banking Federation · filed 18 Nov 2021 · source
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.
CINOA · filed 29 Nov 2021 · source
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.
CINOA · filed 29 Nov 2021 · source
CINOA understands that Member States are responsible for the establishment but remain free to introduce rules going beyond those laid out in the package of proposals of which this draft Directive is a part, but only if they are justified on a risk-based approach.
European Banking Federation · filed 29 Nov 2021 · source
The European Banking Federation (EBF) supports the objectives of the European Commission’s Anti-Money Laundering and Countering the Financing of Terrorism Package which aims to strengthen the fight against financial crime in Europe. The set-up of a new EU AML Authority (AMLA) is a crucial component of this package.
CINOA · filed 11 Mar 2020 · source
CINOA is the principal international confederation of art & antique dealer associations (www.cinoa.org). Established in 1935, CINOA is the global leader in representing the international art and antiques trade, setting benchmark standards for the industry and promoting a responsible art trade.
European Banking Federation · filed 11 Mar 2020 · source
Dear Sir/Madam, Please find enclosed a word (light) version of "LIFTING THE SPELL OF DIRTY MONEY", EBF BLUEPRINT FOR AN EFFECTIVE EU FRAMEWORK TO FIGHT MONEY LAUNDERING A full pdf version is available at: https://www.ebf.eu/wp-content/uploads/2020/03/EBF-Blueprint-for-an-effective-EU-framework-to-fight-money-laundering-Lifting-the-Spell-of-Dirty-Money-.pdf Best regards, [name removed]
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