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.
Company · Germany
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.
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).
Deutscher Notarverein · filed 18 Nov 2021 · source
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:
Filed in German · English published by the European Commission
Deutscher Notarverein · filed 18 Nov 2021 · source
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:
Filed in German · English published by the European Commission
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.
Deutscher Notarverein · filed 18 Nov 2021 · source
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:
Filed in German · English published by the European Commission
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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