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Compare organizations

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.

GIA
German Insurance Association (GDV)

Industry association · Germany

35
files engaged
of 583 tracked
44
positions filed
in those 583 files
13.3
declared FTE
self-declared
9
EP accreditations
as declared to the register

Declared costs: €2.8M+ a year · in the register since 2008

Files both filed on (2)

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.

What each said, in their own words

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.

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

Pepdata · filed 2 Nov 2021 · source

Pepdata strongly welcomes the ambitious package of legislative proposals presented by the European Commission on the 20th of July to strengthen and uniformize the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules.

Pepdata · filed 2 Nov 2021 · source

Pepdata strongly welcomes the ambitious package of legislative proposals presented by the European Commission on the 14th of July to strengthen and uniformize the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules.

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.

Anti-Money Laundering Authority (AMLA)

Pepdata · filed 2 Nov 2021 · source

Pepdata strongly welcomes the ambitious package of legislative proposals presented by the European Commission on the 14th of July to strengthen and uniformize the EU’s anti-money laundering and countering the financing of terrorism (AML/CFT) rules.

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.

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