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: €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.
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.
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 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.
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
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